The 1884 U.S. Supreme Court case Hurtado v. California declared that

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Hurtado v. California declared that states did not have to provide a grand jury. The case was brought forth by Joaquin Hurtado, who argued that he was denied due process under the Fourteenth Amendment because he was not indicted by a grand jury. The Supreme Court ultimately ruled that the Fifth Amendment's requirement for a grand jury only applied to federal cases, and therefore states were not required to provide one for state criminal trials.