The Indian Civil Rights Act (ICRA) requires that no tribe shall “deny to any person accused of an offense punishable by imprisonment the right, upon request, to a trial by jury of not less than six persons.” 1 In addition, the Special Domestic Violence Criminal Jurisdiction (SDVCJ) of the 2013 Violence Against Women Act (VAWA) requires “an impartial jury that is drawn from sources that reflect a fair cross-section of the community; and do not systematically exclude any distinctive group in the community, including non-Indians.” 2 This requirement exists in cases where imprisonment of any length of time is possible.