7th Amendment
“In Suits at common law, where the value in controversy shall exceed twenty dollars, the right of trial by jury shall be preserved, and 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.”
What Does It Mean?
The Seventh Amendment guarantees the right to a jury trial in civil cases in federal court, and it sets limits on when courts can overturn a jury's factual decisions. This right has its origins in English common law and was significant during the colonial period. Interestingly, it was initially left out of the Constitution. However, the First Congress eventually added it to the Bill of Rights in 1791.
Over time, the Supreme Court has understood the phrase "Suits at common law" in the Amendment to mean that the right to a jury trial in civil cases should follow the English common law practices as they existed when the Amendment was adopted. This implies that the right doesn't extend to cases in admiralty and maritime law or to other proceedings historically handled by a judge instead of a jury. It also doesn't cover statutory proceedings that involve new types of legal rights created by Congress.
The essays in this section provide more in-depth information about the historical context of the right to jury trials in civil cases, the specific kinds of civil cases and claims that require a jury trial, and other related aspects. This includes discussions about when courts can make decisions that prevent certain claims from going to a jury, how juries are composed and function in civil cases, and the situations where courts can go against a jury's verdict and issue a different judgment..
Right to a Trial by a Jury in Civil Cases
Historical Background of Jury Trials in Civil Cases:
The Seventh Amendment ensures that in federal court, civil cases have the right to a trial by jury. This idea comes from English common law, which can be traced back a long time. It was talked about by Sir William Blackstone, who believed that it was important for fairness in justice. He thought that if only a small group of people made decisions, they might favor people like them.
When the colonists came to America from England, they brought this right with them. It was a big deal during the colonial times. The people in the colonies resisted when the King of England tried to take away this right, and this was one of the things that led to the American Revolution. Even though this right was important in Colonial America, it wasn't included in the first version of the Constitution.
People who were part of the meeting that created the Constitution, called the Philadelphia Convention, talked about including the right to a jury trial twice. On September 12, 1787, Hugh Williamson of North Carolina brought up the fact that there was no rule for juries in civil cases, and he thought there should be. Some people agreed, but they saw that different states had different ways of doing civil trials, so it would be hard to make a single rule.
After the Convention, when people were deciding if they should agree to the Constitution, many who were against it made a big deal about the lack of a right to a jury trial. They thought that if the Constitution didn't say there should be juries in civil cases, then juries wouldn't be used in those cases anymore. But Alexander Hamilton, who wrote the Federalist Papers, argued that the Constitution not talking about civil juries just meant that things would stay how they were in the state laws.
When the Constitution was being approved, some states said Congress should make an amendment to guarantee the right to a jury trial in civil cases. James Madison, who proposed the Bill of Rights, added this right to the list of amendments. It became part of the Bill of Rights in 1791, and it's known as the Seventh Amendment.
Identifying Civil Cases Requiring a Jury Trial:
The Seventh Amendment guarantees the right to a jury trial in certain types of civil cases called "Suits at common law." The Supreme Court has clarified that this applies to legal rights and remedies that were traditionally dealt with in courts of law, rather than in equity or admiralty courts. The term "common law" was used to make it clear that this right doesn't cover cases involving equitable rights or remedies that were handled differently when the Amendment was created.
The Supreme Court has made important decisions about this. In one case, a landlord wanted to take back property from a tenant who hadn't paid rent. The Court said that even if this wasn't exactly the same as a situation in England in 1791, it still qualified for a jury trial because it had similar aspects to cases where a jury trial was common.
In another case, someone claimed they were treated unfairly based on their race when renting a home. The Court said that the Seventh Amendment does apply to cases involving rights created by statutes. If the statute gives legal rights and remedies that can be settled by a damages lawsuit, then a jury trial can be requested.
However, there are exceptions. The Seventh Amendment doesn't cover cases in admiralty and maritime jurisdiction when a trial is done without a jury. It also doesn't apply to new types of legal proceedings created by statutes, like when a court of equity enforces an order from an administrative body.
The Court has decided that for cases involving public rights where the government enforces public rights created by statutes, the Seventh Amendment doesn't always require a jury trial. But when private rights are involved, like when one person owes something to another, the Seventh Amendment is considered to protect the right to a jury trial.
In the end, the Seventh Amendment secures the right to a jury trial in certain civil cases, but the specific situations can vary based on whether the case involves legal or equitable rights and remedies, and whether it deals with public or private rights.
Cases Combining Law and Equity:
The Seventh Amendment gives the right to a jury trial in certain cases known as "Suits at common law." This means cases involving legal rights and remedies that were usually dealt with in courts of law, not in equity or admiralty courts. The term "common law" was used to clarify that this right doesn't apply to civil cases involving equitable rights and remedies enforced by courts back when the Amendment was made.
There are two cases where the Supreme Court decided that civil juries were necessary, showing how they view this distinction. In the first case, a landlord wanted property back from a tenant who hadn't paid rent based on local laws. The Court said it doesn't matter if this law existed in England back in 1791; what's important is that it has similar aspects to cases that were usually solved by juries in common law.
In another case, someone claimed they were treated unfairly due to their race while renting a house, breaking federal law. The Court disagreed with the idea that the Seventh Amendment doesn't apply to new cases created by Congress. They said the Amendment does apply to cases enforcing legal rights created by statutes, as long as these rights and remedies can be addressed in courts of law.
However, there are exceptions. The Court has allowed cases without a jury when the case isn't what the Amendment meant by "Suits at common law" or when the issues raised aren't exactly legal. When there's no exact historical precedent from when the Amendment was created, the court might also think about whether it's better for judges or juries to handle the case based on existing rules and fairness.
The Seventh Amendment doesn't cover cases involving admiralty and maritime law where there's no jury trial. It also doesn't apply to new kinds of legal proceedings created by statutes, like when a court of equity enforces an administrative body's order. For example, under the Occupational Safety and Health Act, Congress gave an agency the power to find workplace safety violations and give penalties. An employer who gets fined can challenge this in a federal court of appeal. The Supreme Court said that Congress can assign the task of finding facts and making initial decisions about these kinds of cases to an administrative body, even without a jury. But if Congress assigns these cases to Article III courts, then a jury might be needed.
In Tull v. United States, the Court said the Seventh Amendment requires a jury to decide if someone is liable for civil penalties under the Clean Water Act. This Act lets the Environmental Protection Agency start a civil case in a federal court to enforce it. The Court thought that this type of penalty is different from what equity courts give, so it should only be given by courts of law. But deciding the amount of the penalty doesn't need a jury, since it's not a fundamental part of the common-law right to a jury trial.
Later on, the Court used a broader idea of public rights to set limits on Congress's power to send cases to tribunals without juries. Public rights are about the government's relationship with people under its authority, while private rights are about one person's liability to another. In Granfinanciera, S.A. v. Nordberg, the Court said Congress can't take away the right to a jury trial for private matters. The test for this is the same as the test for whether Congress can give a non-Article III tribunal the power to decide a case. The Court decided that a bankruptcy trustee's right to get back money for a fraudulent transfer is more like a private right, especially if the person being sued didn't ask for money from the bankruptcy estate.
Restrictions on the Role of the Judge:
One of the main goals of the Seventh Amendment was to keep a clear distinction between the roles of the jury and the judge, while still allowing new ways of doing things that respect this separation. The Supreme Court has outlined what judges can do during a trial without crossing this boundary:
Judge's Opinion: A federal judge can express their view on the facts, as long as the final decision on the facts is left to the jury.
Highlighting Important Evidence: Judges can point out specific evidence they think is important, but they need to differentiate between matters of law and personal opinion.
Insufficient Evidence: If there's not enough evidence to justify a verdict, a judge can inform the jury.
Specific Questions: Judges can ask the jury to answer specific questions along with giving a general verdict.
Directing Verdict for Defendant: After the plaintiff's case, a judge can tell the jury to decide in favor of the defendant if the evidence is insufficient.
Setting Aside Verdict: A judge can cancel a verdict that goes against the law or evidence and order a new trial.
New Trial Conditions: A judge can deny a defendant a new trial if the plaintiff agrees to lower the damages awarded.
However, in International Terminal Operating Co. v. N.V. Nederl. Amerik Stoomv. Maats., the Court decided that an appeals court was wrong in overturning a jury's decision on whether a stevedoring company's actions were reasonable in preventing an employee's injury. The Court said that according to the Seventh Amendment, this issue should have been decided by the jury.
The Court also mentioned that there are situations where judges can limit what goes to a jury without breaking the Seventh Amendment. For example, to filter out weak complaints or defenses, Congress has the power to decide what needs to be included in a claim, just like they have the power to set out what needs to be proven to win a case. This is part of the federal lawmaker's ability to shape how private actions are dealt with.
Composition and Functions of a Jury in Civil Cases:
The Supreme Court has historically seen the Seventh Amendment as safeguarding the right to a jury trial in civil cases, just as it was in English common law when the amendment was established. This right involved a jury of twelve people, overseen by a judge who could guide them on the law and facts, and could set aside their decision if it seemed against the law or evidence. The jury had to reach a unanimous decision.
In the case of Colgrove v. Battin, though, the Court ruled 5-4 that rules allowing civil juries with six members in federal district courts were acceptable under the Seventh Amendment and federal law. The Court believed that the amendment's mention of common law meant it was meant to preserve the idea of jury trials in civil cases as they existed in common law, rather than sticking to specific details.
As mentioned, a key aim of the Seventh Amendment is to maintain the division between the roles of the court and the jury. The court handles matters of law, while the jury decides on matters of fact based on the court's guidance. The amendment doesn't demand keeping old procedures or prevent the introduction of new methods for finding facts or new evidence rules. The Court's stance is that cases that were tried by a jury in England back in 1791 should still be tried by a jury today. Similarly, cases that were traditionally dealt with by a judge, like those in equity and admiralty law, should still be handled that way now. When new rights and remedies are introduced, the Court considers whether they match their historical counterparts in law or equity to determine if a jury trial is appropriate, unless Congress specifies otherwise.
Reexamination Clause
Review of Evidentiary Record:
The Reexamination Clause of the Seventh Amendment prevents the reexamination of facts tried by a jury in federal courts, except according to common law rules. In the case of Slocum v. New York Life Insurance Co. in 1913, the Supreme Court ruled that a federal appeals court lacked the authority to issue a judgment opposing the verdict of a trial court. Even though the Court agreed that the trial court should have directed a verdict for the defendant before the jury's decision, they believed that once the trial court chose not to do so and the jury decided in favor of the plaintiff against the evidence, the only option for either court was to order a new trial. This decision was met with criticism and subsequent cases challenged or limited its scope.
In Baltimore & Carolina Line v. Redman, the Court held that a trial court could enter a judgment for the plaintiff based on a jury's verdict, even after initially reserving judgment on the defendant's motion for a directed verdict. The Court distinguished this case from Slocum, suggesting that Slocum's assertions were partly modified by this new ruling.
In Lyon v. Mutual Benefit Ass'n, the Court supported a district court's decision to reject the defendant's dismissal motion and directly order a verdict for the plaintiff. The Court deemed the evidence sufficient for the verdict and agreed that the trial court acted within the Federal Conformity Act and Arkansas's procedure in the diversity action.
In Galloway v. United States, where an action was brought against the government for insurance benefits, the trial court directed a verdict in favor of the government due to insufficient evidence. Both the appeals court and the Supreme Court upheld this decision. However, some Justices, like Hugo Black, expressed dissent, believing that this trend of decisions over the years has eroded a significant part of the Seventh Amendment's protections.
The Court has faced challenges in reconciling the historic common law principles that guide the interactions between judges and juries with the concept of an evolving common law.
Appeals from State Courts to the Supreme Court:
The clause in the Seventh Amendment that prevents re-examination of jury findings isn't limited to cases heard by juries in federal courts only. It also applies to cases tried before a jury in a state court and then appealed to the Supreme Court. However, the Supreme Court has indicated that in cases where there's a claim of a violation of constitutional rights, it can review the evidence on which the lower court based its decisions. This stance might clash with the principle of jury independence under certain circumstances.
