White v. Commonwealth

Martin C. White, the defendant, failed to appear on the date set for his trial on a charge of reckless driving. The trial court, after an evidentiary hearing without a jury, 1 found the defendant guilty as charged and fixed his punishment at a fine of $150 and 30 days in jail.

We must determine whether the jail sentence passes muster under the Sixth Amendment in light of Argersinger v. Hamlin, 407 U.S. 25 (1972), which held “... that absent a knowing and intelligent waiver, no person may be imprisoned for any offense, whether classified as petty, misdemeanor, or felony, unless he was…