An anti-abortion protester arrested for blocking access to a clinic had no right to a jury trial on a charge of violating the Freedom of Access to Clinic Entrances Act, a federal appeals court has ruled.

The U.S. Court of Appeals for the Second Circuit said in United States v. Dugan, 10-4248-cr, that a violation of the act was a “petty” offense that did not entitle defendant Richard R. Dugan to trial by jury.