Federal courts historically have had the power to try criminal contempt cases without a jury. There is a virtually uninterrupted 150-year line of cases which holds that contempt is not a "Crime" or "criminal prosecution" within the meaning of article III and the sixth amendment to the Constitution. Superficially, the decision in United States v. Barnett is in accord with these precedents. However, in an important "dictum," footnote number 12, the majority cautioned that "punishment by summary trial without a jury would be constitutionally limited to that penalty provided for petty offenses." Although the Court itself styles this comment a dictum, its potential effect is to overrule this long history of decisions.
Michigan Law Review,
Constitutional Right to Jury Trial in Criminal Contempt Cases?-United States v. Barnett,
Mich. L. Rev.
Available at: https://repository.law.umich.edu/mlr/vol63/iss4/5