Omar Bennett
The Seventh Amendment of the United States Constitution guarantees the right to a civil jury trial. The amendment states that in suits at common law, where the value in controversy exceeds twenty dollars, the right to a trial by jury shall be preserved. This amendment is significant as it ensures that individuals have the right to a jury trial in certain civil cases, providing a layer of protection against arbitrary power and potential bias in the judicial system. The Seventh Amendment also includes a Re-examination Clause, which prohibits the re-examination of facts tried by a jury in any Court of the United States, further safeguarding the rights of individuals.
| Characteristics | Values |
|---|---|
| Civil jury trial | Guaranteed in federal and state constitutions |
| Jury size | Minimum of six members |
| Monetary threshold | Exceeds $20 (in 1791) or $500 (in 2024) |
| Re-examination Clause | No fact tried by a jury shall be re-examined in any US Court |
| Applicability | Does not apply to cases under maritime law, lawsuits against the government, or patent claims |
| Interpretation | Based on English common law and civil jury tradition |
| State-level application | Not required to provide jury trials in civil cases, but most states voluntarily guarantee this right |
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What You'll Learn
Jury trials in civil cases
The Seventh Amendment of the US Constitution guarantees the right to a jury trial in civil cases. This right has been a point of contention, with Anti-Federalists arguing for its inclusion to prevent arbitrary power and protect litigants from bad laws, tyrannical executives, and corrupt or biased judges. James Madison drafted the Seventh Amendment to address these concerns.
The amendment's provision for jury trials in civil cases has never been directly applied to the states, as per the Supreme Court rulings in Walker v. Sauvinet (1875), Minneapolis & St. Louis Railroad v. Bombolis (1916), and Hardware Dealers' Mut. Fire Ins. Co. of Wisconsin v. Glidden Co. (1931). However, almost every state has voluntarily included this right in their constitutions.
The Seventh Amendment sets a minimum of six members for a jury in a civil trial. It also establishes a monetary threshold, stating that in "Suits at common law, where the value in controversy shall exceed twenty dollars, the right of trial by jury shall be preserved." This threshold, set in the late 18th century, has not been adjusted for inflation and remains at $20 despite its diminished value over time.
The amendment also includes a Re-examination Clause, which states that "no fact tried by a jury, shall be otherwise re-examined in any Court of the United States, than according to the rules of the common law." This clause ensures that the findings of a jury trial cannot be overturned, applying to federal cases, state cases involving federal law, and federal court reviews of state cases.
The interpretation of the Seventh Amendment has been influenced by English common law, as established in United States v. Wonson (1812) and further supported by Justice Joseph Story's ruling in Wonson. This interpretation led to the conclusion that jury trials are not constitutionally mandated in cases under maritime law, lawsuits against the government, and certain patent claims.
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Jury size in civil trials
The Seventh Amendment of the United States Constitution guarantees several rights related to civil jury trials. One of these rights is the provision for a minimum jury size of six members in civil trials. This guarantee ensures that individuals involved in civil cases have their cases heard and decided upon by a jury comprising at least six individuals.
The Seventh Amendment is considered one of the more straightforward amendments of the Bill of Rights. It addresses the role and importance of jury trials in civil cases, aiming to protect individuals' rights during legal proceedings. The amendment's provision for a minimum jury size of six members is a key aspect of this protection.
The inclusion of this minimum jury size requirement in the Seventh Amendment reflects the historical significance of the civil jury in the English legal system, which served as a precursor to the American legal system. The civil jury was an institution in England, even older than the criminal jury, where individuals not trained in law would decide on certain civil cases.
While the Seventh Amendment guarantees a minimum jury size, it is important to note that it does not guarantee a jury trial in all civil cases. There are exceptions, such as cases under maritime law, lawsuits against the government, and certain patent claims. Additionally, the Supreme Court has ruled that the right to a civil jury trial is not a fundamental right, so states are not obligated to conduct them. However, most states voluntarily guarantee this right, and they are required to do so in certain state court cases decided under federal law.
The Seventh Amendment's guarantee of a minimum jury size of six members in civil trials is a crucial aspect of the amendment's protection of individuals' rights during legal proceedings. By ensuring a diverse group of individuals decides on civil cases, this provision helps maintain impartiality and fairness in the justice system.
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The Re-examination Clause
The Seventh Amendment of the United States Constitution contains two clauses, the second of which is known as the Re-examination Clause. This clause states:
> "no fact tried by [a] jury, shall be otherwise re-examined in any Court of the United States, than according to the rules of the common law."
The term "common law" in the Re-examination Clause refers to the law and procedure of the courts that used juries, as opposed to Equity and other courts that did not use juries. In other words, it refers to the English common law of 1791, which governed the types of cases that juries decided and the ways that judges could review their verdicts.
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The role of Congress
The Seventh Amendment of the United States Constitution guarantees the right to a civil jury trial. The amendment states that in "suits at common law", where the value in controversy exceeds twenty dollars, the right to a trial by jury shall be preserved. This amendment ensures that no fact tried by a jury shall be re-examined in any United States Court, except according to the rules of common law.
Initially, Congress resisted the inclusion of the Seventh Amendment, with Federalists like Madison and Alexander Hamilton arguing for congressional control over jury trial availability. However, the Anti-Federalists prevailed, and the Seventh Amendment was ratified. This amendment effectively prohibited Congress from unilaterally denying Americans their right to a civil jury trial.
Despite this, Congress has found ways to circumvent the Seventh Amendment in certain cases. In Atlas Roofing Co. v. Occupational Safety and Health Review Commission (1977), the plaintiff challenged the imposition of a civil monetary penalty for a violation of workplace safety regulations, arguing that the Seventh Amendment guaranteed them a jury trial. The Court rejected this argument, stating that "new causes of action, and remedies therefore, unknown to the common law" could be decided by administrative agencies, even if similar claims would typically require a jury in federal court. This ruling created a loophole, allowing Congress to potentially deny civil jury trial rights by assigning cases to administrative agencies.
In conclusion, while the Seventh Amendment restricts congressional power over civil jury trials, Congress has found ways to work around these limitations. The ongoing interpretation and application of the Seventh Amendment continue to shape the role of Congress in preserving the right to a civil jury trial.
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The historical test
The Seventh Amendment of the United States Constitution guarantees the right to a civil jury trial. The text of the amendment states that "in suits at common law... the right of trial by jury shall be preserved". This right is not limited to the "common-law forms of action recognised" when the amendment was ratified.
Despite the Seventh Amendment's guarantee, the Supreme Court has ruled that the civil jury trial right is not a fundamental right, and therefore states are not obligated to hold civil jury trials. However, most states voluntarily guarantee this right, and they must do so in certain state court cases decided under federal law.
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Frequently asked questions
The Seventh Amendment of the United States Constitution guarantees the right to a civil jury trial in certain cases.
The Seventh Amendment applies to "suits at common law" where the value in controversy exceeds twenty dollars. It does not apply to cases under maritime law, lawsuits against the government, or many parts of patent claims.
The Seventh Amendment was drafted by James Madison in response to the Anti-Federalists' protests against the lack of a right to a civil jury trial. The Anti-Federalists argued that jury trials were necessary to protect litigants from bad laws, tyrannical executive actions, and corrupt or biased judges.
