More than 40 countries have jury duty in some form, but what that duty looks like depends entirely on where you live. Some countries hand the verdict to a panel of ordinary citizens who deliberate on their own. Others seat laypeople next to professional judges on a shared bench. A smaller group lets citizens vote but allows the judge to override them, and many countries use no lay participation at all. The practical difference between serving in the United States, Germany, Japan, and Brazil is large enough that the term covers very different experiences.
Countries With Traditional Juries
Traditional jury systems seat lay citizens who decide the facts of a case independently from the judge. The judge handles legal questions and courtroom management; the verdict belongs to the jurors. The model comes out of English common law and is strongest in countries that inherited that tradition.
The United States has the broadest jury system in the world. The Sixth Amendment guarantees a jury trial in criminal cases, and the Seventh Amendment preserves it for most federal civil disputes. Federal criminal juries have 12 members, and the Supreme Court confirmed in 2020 that a unanimous verdict is required to convict in both federal and state criminal trials.1Supreme Court of the United States. Ramos v. Louisiana, No. 18-5924 Federal civil juries can run from 6 to 12 members, and their verdicts also have to be unanimous unless the parties agree otherwise.2Legal Information Institute. Federal Rules of Civil Procedure, Rule 48 – Number of Jurors; Verdict; Polling
In England and Wales, serious criminal offenses go to the Crown Court, where 12 randomly selected jurors decide guilt.3UK Parliament. Court Statistics for England and Wales Canada seats 12 jurors in criminal cases and requires unanimity.4Justice Canada. The Role of the Public – About Canada’s System of Justice Anyone facing a maximum sentence of five years or more has a constitutional right to a jury trial under Section 11(f) of the Canadian Charter of Rights and Freedoms.5Department of Justice Canada. Section 11(f) – Trial by Jury Australia, New Zealand, and Ireland use the same 12-person common-law model with few changes.
Russia brought back jury trials in 1993 after they had disappeared under the Soviet system. A 2016 reform that took effect in 2018 reshaped the structure: regional courts seat 8 jurors for the most serious offenses, and district courts use 6-person juries for grave crimes such as murder. Russian defendants can choose a jury or trial by professional judges.
Spain is the only European civil-law country to have adopted a common-law-style jury. Under the 1995 Organic Law on the Jury, nine citizens and one presiding magistrate handle a defined list of criminal offenses, with the jurors deciding guilt on their own and the magistrate staying out of their deliberations.6Office of Justice Programs. Lay Participation in Spain – The Jury System
Countries With Mixed Panels of Citizens and Judges
Many countries put citizens in the courtroom but have them share the bench with professional judges rather than deliberate alone. These mixed tribunals are common in continental Europe and parts of East Asia. Lay participants typically vote with the professional judges on both guilt and sentencing.
Germany’s criminal courts include lay judges called Schöffen who serve as equal members of the panel. In lower courts, two Schöffen sit with one professional judge; in higher courts, two join three professionals. Local councils nominate candidates and a two-thirds majority adds someone to the list. Schöffen typically serve five-year terms and participate in every decision, including procedural rulings, verdict, and sentencing. Any decision against the defendant requires a two-thirds majority of the full panel.
France uses a mixed system in its cour d’assises for the gravest crimes, including murder, armed robbery, and terrorism. Three professional judges sit with six citizen jurors at first instance, or nine on appeal.7Service Public. Juror of Assize Everyone deliberates together and votes by secret ballot on both guilt and sentencing, with each juror’s vote carrying the same weight as a judge’s.
Japan launched its saiban-in system in 2009. Six citizens drawn from the public sit with three professional judges to try serious criminal cases, including those punishable by death or life imprisonment.8The Ministry of Justice. Please Cooperate With the Saiban-in (Lay Judge) System Decisions require a majority that must include at least one professional judge, so the lay judges cannot convict or acquit on their own.
South Korea introduced citizen participatory trials in 2008. Seven jurors hear cases carrying imprisonment of one year or more, and nine sit for death penalty or life imprisonment cases. The jurors first try to reach a unanimous verdict and may hear from the presiding judges before deciding by majority if they can’t. Their verdict is advisory, however, and judges can override it, though in practice they usually follow it.9Library of Congress. Citizen Participatory Trials in South Korea
Brazil reserves jury trials for intentional crimes against life, including murder and assisted suicide. Seven jurors hear these cases, but they never deliberate with each other. Each juror votes secretly and individually on questions posed by the judge, and four votes convict.
China uses “people’s assessors” who sit with professional judges. A 2018 reform created two panel types. On three-member panels, assessors vote on all questions. On seven-member panels, four assessors can take part in fact-finding but have no vote on legal questions or sentencing.10Supreme People’s Court of the People’s Republic of China. China Has Over 341,000 People’s Assessors
Denmark, Sweden, and Norway all use lay judges who sit with professional judges on both verdict and sentencing. These Nordic systems resemble Germany’s Schöffen model more than they resemble common-law juries.
Countries With No Juries or Lay Judges
A large share of the world’s legal systems rely entirely on professional judges. That is the norm across much of the Middle East, much of Africa, and in several Asian countries including Singapore, Malaysia, and Pakistan. Trained judges evaluate the evidence, decide guilt, and impose sentence.
The Netherlands is a notable European example. Dutch courts use only professional judges, with safeguards built in to protect fairness. Judges must recuse themselves whenever there is any appearance of bias, and parties can formally challenge a judge’s impartiality through a process called wraking. Cases are assigned on objective pre-established criteria, which blocks litigants from steering a case to a sympathetic judge.11De Rechtspraak. Matters of Principle – Codes on the Independence and Impartiality of the Judiciary
India once had jury trials and deliberately abandoned them. After the controversial 1959 acquittal of naval officer K.M. Nanavati, widely seen as driven by public sympathy rather than evidence, the country phased out juries. Professional judges now handle all criminal and civil cases.
How Jury Duty Works in the United States
Because the United States has the broadest jury system of any country, the practical side of serving is worth knowing. It covers who qualifies, what you’re paid, what your employer can and can’t do, and what happens if you ignore a summons.
Who Qualifies and Who Is Exempt
Federal jury service requires you to be a U.S. citizen, at least 18, and a resident of the judicial district for at least one year.12Office of the Law Revision Counsel. 28 USC 1865 – Qualifications for Jury Service A felony conviction disqualifies you, as does inability to read and understand English well enough to follow the proceedings. Active-duty military, professional police and firefighters, and full-time elected or appointed public officials are exempt outright.13United States Courts. Juror Qualifications, Exemptions and Excuses
Courts may also permanently excuse people over 70, anyone who served on a federal jury within the past two years, and volunteer firefighters or emergency responders.13United States Courts. Juror Qualifications, Exemptions and Excuses Beyond those categories, a court can defer service for undue hardship or extreme inconvenience on request.
Pay and Job Protection
Federal jurors receive $50 per day plus a mileage allowance.14Office of the Law Revision Counsel. 28 USC 1871 – Fees State courts pay considerably less, averaging around $22 per day nationally, and a few states pay nothing. Federal law does not require your employer to pay your regular wages during jury service, and most states follow the same approach, though some mandate some level of paid leave.
Your job itself is protected. Federal law prohibits any employer from firing, threatening, or intimidating an employee because of jury service. An employer who violates that rule faces liability for lost wages, a court order to reinstate the employee, and a civil penalty of up to $5,000 per violation.15Office of the Law Revision Counsel. 28 USC 1875 – Protection of Jurors’ Employment When you return, the law treats your time away as a leave of absence, preserving seniority and benefits.
What Happens If You Ignore a Summons
Skipping jury duty is not a minor matter. Under federal law, failing to show good cause for not appearing can bring a fine of up to $1,000, up to three days in jail, mandatory community service, or any combination of those. State courts impose similar consequences, and some judges issue a bench warrant for repeat no-shows. If you genuinely cannot serve on the date assigned, request a deferral in advance.