A West Palm Beach chiropractor is now at the center of a Supreme Court case that could change thousands of criminal convictions across six states. The question sounds almost mundane: how many people have to sit on a jury? The answer the Court gives could change criminal court cases across the country forever.
Hamed Kian was charged in Florida with five counts of practicing chiropractic medicine with a suspended license, a felony that carries up to five years in prison. Under Florida law, only capital cases require a 12-person jury. Everything else, including Kian’s case, gets six. The trial court empaneled six jurors as Florida law dictates, Kian’s attorney fully participated in jury selection without objecting to the panel’s size, and the jury returned unanimous guilty verdicts on all five counts. He was sentenced to a year and a day in prison on three counts, running concurrently, followed by five years of probation on two more, running consecutively.
On appeal, Kian argued for the first time that the Sixth Amendment entitled him to a 12-person jury. Florida’s Fourth District Court of Appeal rejected that argument in a short, unsigned decision. That kind of ruling is called “per curiam”: the court decides the case without a full written opinion explaining its reasoning, which usually signals the judges thought the outcome was clear.
The Supreme Court agreed to hear the case in June 2026. The question the Court will answer: whether Kian was deprived of his right, under the Sixth and Fourteenth Amendments, to a trial by a 12-person jury when charged with a serious felony.
Both amendments matter here because of a doctrine called incorporation. The Sixth Amendment’s text applies to the federal government, but the Supreme Court has held that most Bill of Rights protections also bind state governments through the Fourteenth Amendment. That’s why a case about a Florida state prosecution is a federal constitutional question at all.
In 1970, the Supreme Court decided Williams v. Florida, ruling that Florida’s use of six-person juries in noncapital cases satisfies the Sixth Amendment. The Court spent dozens of pages examining the history of the jury right and concluded that the number twelve was, in its words, a “historical accident” rather than something the Constitution required.
That’s the precedent Kian is asking the Court to overturn. His lawyers argue the twelve-person jury traces back centuries, through English common law, and that the writers assumed it when they wrote the Sixth Amendment. They also point to research suggesting smaller juries deliberate less thoroughly and represent communities less fairly, and they’ve raised a more another historical claim: Florida adopted its six-person jury rule in 1877, the same year federal troops left the state after Reconstruction, and Kian’s team that it was done to dilute the influence of Black jurors.
Florida argues differently. The state says it kept twelve-person juries for capital cases even after the 1877 law took effect, which it says shows there was no racial motive, and it points to its current state constitution, adopted in 1968, as further evidence the six-person rule isn’t a relic of Jim Crow. Florida also pushes back on the other argument, citing its own data showing that Florida’s felony conviction rates in recent years were comparable to, and sometimes lower than, states that use twelve-person juries.
Kian leans heavily on a more recent case to make his central legal argument: Ramos v. Louisiana, decided in 2020, in which the Supreme Court ruled that the Sixth Amendment requires unanimous jury verdicts in state trials, not just federal ones. Kian argues that Ramos’s reasoning, rooted in what the jury right meant historically, effectively undercuts Williams too. If unanimity was constitutionally locked in based on founding-era practice, why wasn’t jury size?
Florida answers that Williams and the case Ramos overturned (Apodaca v. Oregon) aren’t comparable. Apodaca never got a majority ruling, but Williams had been repeatedly reaffirmed by the Court for over fifty years. Florida also argues that just because the jury had to be unanimous doesn’t mean it had to be a specific size. Both features existed at common law, but the Court can treat them differently.
In 2022, the Court declined to hear a similar challenge to Arizona’s eight-person juries, called Khorrami v. Arizona. Justice Neil Gorsuch dissented that denial, writing that the historical evidence shows the right to a jury trial for serious crimes meant a trial before twelve members of the community, nothing less.
Florida has a fallback argument even if the Court doesn’t buy any of the above: it says this case is a bad one to use for revisiting Williams, because even a smaller jury didn’t affect the outcome here. The evidence against Kian, Florida argues, was overwhelming, so any constitutional error would be “harmless” and wouldn’t entitle him to a new trial regardless of how the Court rules on jury size. This matters because most constitutional trial errors get evaluated for whether they actually changed the result. Only a small category of “structural errors,” ones considered so fundamental that courts don’t even ask whether they mattered, automatically require a new trial. Florida argues jury size doesn’t belong in that category, so even a win for Kian on the big constitutional question might not undo his conviction.
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