Seventh Amendment to the United States Constitution

[1] United States v. Wonson (1812) established the historical test, which interpreted the amendment as relying on English common law to determine whether a jury trial was necessary in a civil suit.

[7] One charge of the Anti-Federalists was that giving the U.S. Supreme Court jurisdiction "both as to law and fact" would allow it to deny the findings of jury trials in civil cases.

Responding to these concerns, five state ratification conventions recommended a constitutional amendment guaranteeing the right to jury trial in civil cases.

Many Anti-Federalists, in contrast, now opposed it, realizing the Bill's adoption would greatly lessen the chances of a second constitutional convention, which they desired.

[12] Anti-Federalists such as Richard Henry Lee also argued that the Bill left the most objectionable portions of the Constitution, such as the federal judiciary and direct taxation, intact.

Virginia initially postponed its debate, but after Vermont was admitted to the Union in 1791, the total number of states needed for ratification rose to eleven.

[13] Secretary of State Thomas Jefferson announced the adoption of the ten successfully ratified amendments on March 1, 1792.

[16] The Legal Information Institute stated with respect to the Preservation Clause: "Sir William Blackstone, in his influential treatise on English common law, called the right 'the glory of the English law' and necessary for '[t]he impartial administration of justice', which, if 'entirely entrusted to the magistracy, a select body of men', would be subject 'frequently [to] an involuntary bias towards those of their own rank and dignity'.

The Supreme Court stated in Walker v. Sauvinet (1875), Minneapolis & St. Louis Railroad v. Bombolis (1916) and Hardware Dealers' Mut.

[23]Wonson's ruling established the historical test, which interpreted the amendment as relying on English common law to determine whether a jury trial was necessary in a civil suit.

The Court further clarified this rule as a fixed historical test in Thompson v. Utah (1898), which established that the relevant guide was English common law of 1791, rather than that of the present day.

[24] "The amendment not only preserves that right, but discloses a studied purpose to protect it from indirect impairment through possible enlargements of the power of reexamination existing under the common law, and, to that end, declares that 'no fact tried by a jury shall be otherwise reexamined in any Court of the United States, than according to the rules of the common law'.

"[25] In Baltimore & Carolina Line, Inc. v. Redman (1935), the Supreme Court held that the amendment does not include "mere matters of form or procedure", but instead preserves the "substance" of the right to jury trial.

... By common law, (the Framers of the Amendment) meant ... not merely suits, which the common law recognized among its old and settled proceedings, but suits in which legal rights were to be ascertained and determined, in contradistinction to those where equitable rights alone were recognized, and equitable remedies were administered ...

In a just sense, the amendment then may well be construed to embrace all suits which are not of equity and admiralty jurisdiction, whatever might be the peculiar form which they may assume to settle legal rights."

Although the cause of action arose under the Clean Water Act, the Court surveyed early cases to show that the statutory nature of the claim was not legally relevant.

[19] The Court extended the amendment's guarantees in Beacon Theatres v. Westover (1959) and Dairy Queen, Inc. v. Wood (1962), ruling in each case that all issues that required trial by jury under English common law also required trial by jury under the Seventh Amendment.

[19] In Markman v. Westview Instruments, Inc. (1996), the Court ruled that many parts of patent claims are questions of law rather than of fact, and that the Seventh Amendment guarantee of a jury trial therefore does not necessarily apply.

Lawsuits against the federal government itself do not receive Seventh Amendment protections due to the doctrine of sovereign immunity.

A Harvard Law Review article described it as "mysterious ... of shrouded origin and neglected for two centuries", stating that "no one believes that the Clause bears on the right protected by the Seventh Amendment".

[31] According to law professor Philip Hamburger, the twenty-dollar requirement was intended to become obsolete by inflation, so that its application to more cases would be phased out gradually.

[35][36] Exceptions to this prohibition are possible if it is later determined that legal errors were made or evidence submitted was insufficient in some way.

274 (1869), the Supreme Court quoted Justice Joseph Story to explain the modes to reexamine facts tried by juries according to common law: "Mr. Justice Story ... referring to this part of the amendment, observed ... that it was 'a prohibition to the courts of the United States to re-examine any facts tried by a jury in any other manner [than according to Common Law]'. ...