Bloom v. Illinois
Is it still good law? What later courts have actually done to this case.
Status
More on how this was screened
Of 74 flagged citations, 71 have been read; the text of the other three could not be retrieved. Most nearby “overruled” and “abrogated” words describe Bloom's treatment of older no-jury cases, not treatment of Bloom.
1,167 later cases cite Bloom v. Illinois; 74 of those citations sat close to treatment language and were flagged for reading; 71 of them have been read, and the text of 3 citing opinions could not be retrieved, so those remain unread. Citations that did not sit near treatment language were not flagged and were not read one by one, so a court that weakened this case without using any of that language would not appear here.
Relying on Bloom v. Illinois?
This page shows what later courts did to it. Ask about your specific facts and see whether it still carries your argument, with citations you can check.
Treatments
Limited
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The court declined to extend Bloom's jury-trial principle to a juvenile delinquency proceeding.
State v. Turner · Supreme Court of Oregon · filed
The general language used in Gault, Duncam, and Bloom thus would be broad enough to justify an anticipatory holding that due process includes the right to trial by jury when a child, as well as an adult, faces a substantial loss of liberty. But the general language in these cases has not answered the functional question whether the difference between a child and an adult justifies a difference in the analysis of the role of the jury as a fact-finding instrument. ... Counsel have provided us with no data, and we have found none, relevant to the peculiar problems of children which would justify a holding at this time that due process of law cannot be afforded children without the intervention of a traditional jury as employed in criminal cases.
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The court held that Bloom did not extend the contempt jury right to venue or displace the existing contempt venue rule.
United States v. Twentieth Century-Fox Film Corp. · S.D.N.Y. · filed
Ms. Goldstein’s assertion that the Court’s decision in Bloom v. Illinois, 391 U.S. 194, 88 S.Ct. 1477, 20 L.Ed.2d 522 (1968), overruled Myers is not well taken. A careful reading of Bloom and its progeny show that the Court has avoided characterizing contempt proceedings as criminal proceedings entitled to all the protections of the Sixth Amendment.
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The court held that Bloom did not require trial in the county where the indirect contempt occurred or every state criminal-procedure protection.
People v. Fields · Illinois Appellate Court, Fourth District · filed
Nothing in the United States Supreme Court decision in Bloom indicates that due process necessarily requires a person be tried for indirect criminal contempt in the county where the contempt occurred nor does the opinion indicate due process requires that a person charged with contempt be given all of the protection given by a State to persons charged with crimes.
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The court declined to extend Bloom to require appointed counsel for every direct criminal contempt proceeding.
Plank v. State · Supreme Court of Florida · filed
We reject Plank’s argument that Bloom requires courts to appoint counsel in all direct criminal contempt proceedings. Instead, we conclude thát Bloom impacts only cases in which incarceration is imposed for longer than six months.
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