In District of Columbia v. Colts, the U.S. Supreme Court rules that even though the Sixth Amendment does not make distinctions among trials for different offenses, the right to a jury trial may not apply if the offense is a small one. In 1937, in District of Columbia v. Clawans, the justices will rule that it is unconstitutional to deny a jury trial to a defendant who faces 90 days in jail – 90 days, they decide, is a serious enough punishment to require a jury trial.