I, article 10 of the Vermont Constitution give defendants the right to a jury trial in criminal proceedings.
Some noncriminal proceedings do require a jury, however.
The judge instructed the jury to return a verdict of guilty if he kidnapped any one of the alleged victims, and the jury returned a general verdict. The same strict waiver rules do not apply if the defendant is not waiving a jury altogether, but merely stipulating to a jury of fewer than twelve. By contrast, the sixth amendment allows juries of fewer than twelve, but greater than five. Most other sixth amendment and article 10 rights do apply to delinquency proceedings. Shaw v. Vermont District Court, Unit No.