State v. Resio

In State v. Resio, 148 Wis. 2d 687, 696, 436 N.W.2d 603 (1989), the court created the requirement that the trial court remind the defendant of the unanimous jury requirement before accepting waiver of a jury trial. That rule is a matter of judicial administration, not constitutional necessity. Resio does not address the remedy when the trial court fails to remind the defendant of the unanimous jury requirement. It does not suggest that automatic reversal is required without any showing that the defendant actually lacked that knowledge.