State v. Leroy Reed

Background:

Leroy Reed was a Milwaukee resident with a prior felony conviction. This was due to his assistance as the getaway driver in an armed robbery. He was released early from his sentence as it was determined that he did not realize he was a part of a crime. After he was released, Reed lived a quiet and law abiding life, acting as what many would call a model citizen. Leroy Reed possessed cognitive abilities significantly below average, and was noted to have a second grade reading level even as an adult. He was looking for ways to further improve his life, so he applied for a job as a private investigator, and enrolled in a mail order detective course. Part of the course requirements instructed to purchase a gun, so he did, buying a .22 caliber pistol. It is, however, illegal for a prior convict to own a firearm in the United States. 

The Case:

In 1986, 11 years after Reed had been released from prison, he faced yet another conviction. He was standing outside of a courthouse, hoping someone would approach him and hire him as a private investigator, when a police officer requested him to show identification. He complied, however the only thing he had in his pocket was his proof of buying a firearm, which he handed over without a thought. The officer arrested him, and took him to the police station, where they ran his name and found that he was a prior felon. Some observers have noted, he likely would have gotten away with owning a firearm if it was not for this interaction, as it was left unused in the back of his closet since the day that he bought it.

Debates From Each Side:

The prosecution's position rested on the principle that laws must be enforced consistently. The State argued that because Reed had previously committed a felony, and it was illegal for felons to own firearms based on Wisconsin law, he must be convicted of the crime. His mental limitations were considered irrelevant compared to the legal elements and laws broken from this approach. It was further maintained that personal sympathy should not in any case override legal requirements.

In contrast, the defense, representing Reed, focused on fairness rather than purely strict legal interpretation. It was argued that individual circumstances given Reed’s mental disadvantage must be taken into account. Reed’s representation started by stating that yes, Reed had a felony conviction, and yes, he had purchased a firearm. He turned the debate towards the idea of whether or not Reed had the mental capability to recognize that he had committed a crime.

Verdict:

Despite the fact that many observers believed the prosecution had established the legal elements which would find Reed guilty, the jury declined to convict. The jury chose to exercise the action of jury nullification, voting to acquit Reed. This means that despite evidence suggesting Reed had technically violated the law, jurors chose not to convict. Because acquittals generally cannot be appealed, the verdict stood, meaning this case stayed at trial court level, and did not proceed towards the Supreme Court. 

Legacy:

Despite never making it to the Supreme Court, this case is important as many believed it was decided more based on sympathy rather than rigidly following the law. It highlights the extraordinary power of juries within the American legal system, remaining notable to this day. State v. Leroy Reed raised important legal questions, still debated to this day. Examples of these are: Should juries strictly apply the law as written? Should juries act as a safeguard against laws they view as unjust? Does jury nullification protect liberty, or does it threaten legal consistency? This case emphasizes how in some situations juries can become a final check on government power by refusing to convict when they believe it will not execute justice.