State v. Little
Annotate this CaseThe State filed a complaint against Defendant charging him with third- and fourth-degree criminal sexual conduct. Defendant waived his right to a jury trial during a pretrial hearing. Thereafter, the State filed an amended complaint adding a charge of first-degree criminal sexual conduct. Defendant did not personally waive his right to a jury trial on the amended charge. Defendant was subsequently found guilty of all three counts. Defendant appealed, arguing that the district court erred when it failed to obtain a personal waiver of his right to a jury trial after the State amended the complaint. The court of appeals affirmed Defendant’s first-degree sexual conduct conviction. The Supreme Court reversed the court of appeals, vacated Defendant’s conviction for first-degree criminal sexual conduct, and remanded, holding (1) when the State charges a defendant with an additional offense after the defendant has waived his or her right to a jury trial, the court must obtain a new waiver before dispensing with a jury; and (2) in this case, the district court’s failure to obtain a personal waiver of Defendant’s right to a jury trial on the charge of first-degree criminal sexual conduct constituted a plain error that affected Defendant’s substantial rights.
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