From District of Columbia v. Colts (1930), a Supreme Court case where the issue was whether a criminal offense was merely a “petty offense” and thus not subject to the constitutional jury trial guarantee (emphasis added):
An information filed in the Police Court of the District of Columbia charged the respondent, Colts, with having operated upon various streets, contrary to the statute set frth below, ‘a certain motor vehicle at a greater rate of speed than twenty-two miles an hour over said public highway(s) recklessly, that is to say at a greater rate of speed than was reasonable and proper, having regard to the width of said public highway(s), the use thereof, and the traffic thereon, in such manner and condition so as to endanger property and individuals.’ . . .
An automobile is, potentially, a dangerous instrumentality, as the appalling number of fatalities brought about every day by its operation bear distressing witness. To drive such an instrumentality through the public streets of a city so recklessly ‘as to endanger property and individuals’ is an act of such obvious depravity that to characterize it as a petty offense would be to shock the general moral sense. . . .
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