Seventh Amendment
The Seventh Amendment of the United States Constitution, ratified in 1791 as part of the Bill of Rights, guarantees the right to a jury trial in federal civil cases. This amendment plays a crucial role in distinguishing between issues of law, which are determined by judges, and issues of fact, which juries are tasked with resolving. While the Supreme Court has allowed for civil juries to consist of as few as six members, the amendment does not generally extend to state courts unless enforcing a federally created right. Notably, the amendment has evolved through various Supreme Court interpretations, which have established precedents regarding jury composition and the roles of judges and juries in civil trials. Recent rulings, including a significant 2024 case involving the Securities and Exchange Commission, have reaffirmed the importance of jury trials in protecting defendants' rights. The amendment aims to uphold the common law tradition and ensure that citizens can seek justice through a jury of their peers. Overall, the Seventh Amendment reflects the foundational principles of fairness and equality within the American legal system.
Seventh Amendment
Description: Amendment that guarantees the right to a jury trial in civil common law cases at the federal level.
Significance: The Supreme Court has interpreted this amendment to allow civil juries of six rather than twelve people but has not applied it to civil trials in state courts.
The Seventh Amendment is part of the Bill of Rights was ratified in 1791. It guarantees the right to trial by jury in federal civil cases. The amendment was designed to preserve the common law distinction between issues of law and issues of fact. In Baltimore and Carolina Line v. Redman (1935), the Supreme Court held that the judge should remain the trier of law, deciding unresolved issues of law, and the jury should remain the trier of fact, resolving issues of fact under appropriate instructions by the court.
The amendment’s guarantee applies to all courts under the authority of the United States, including territories and the District of Columbia. Generally, the amendment does not apply to state courts, except when the state court is enforcing a federally created right. When a federal court is enforcing a state-created right, it may follow its own rules based on the interests of the federal court system.
In Colgrove v. Battin (1973), the Court held that a federal district court’s authorization of civil juries composed of six persons instead of the traditional twelve was permissible under the Seventh Amendment; however the Court found in Ballew v. Georgia (1978) that a five-member jury violated the Seventh Amendment. In a unanimous decision in Markman v. Westview Instruments (1996), the Court held that "judges, not juries, are the better suited to find the acquired meaning of patent terms," reasoning that patent claims are questions of law rather than questions of fact.
In June 2024, the Court ruled in Securities and Exchange Commission v. Jarkesy et al. that defendants charged by the Securities and Exchange Commission (SEC) with fraud have the Seventh Amendment right to be tried before a federal jury of one's peers rather than by the independent administrative judges used by the SEC, as authorized by Congress in 2010, to conduct hearings, find facts pertinent to the case, and impose fines. Critics of the decision said that the decision stripped the SEC of its primary tool for penalizing those convicted of fraud against the government.
Bibliography
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Oldham, James. Trial by Jury: The Seventh Amendment and Anglo-American Special Juries. New York UP, 2006.
Seventh Amendment: Civil Trials. GPO, govinfo.gov/content/pkg/GPO-CONAN-2022/pdf/GPO-CONAN-2022-21.pdf. Accessed 1 July 2024.
Sherman, Mark. "The Supreme Court Strips the SEC of a Critical Enforcement Tool in Fraud Cases." AP, 27 June 2024, apnews.com/article/supreme-court-regulatory-agencies-sec-36f16444b1d4fc52985fdb68896362bb. Accessed 1 July 2024.
Supreme Court of the United States. Syllabus: Securities and Exchange Commission v. Jarkesy et al., No. 22–859, Oct. Term 2023, 27 June 2024, www.supremecourt.gov/opinions/23pdf/22-859‗1924.pdf. Accessed 1 July 2024.
Totenberg, Nina. "Supreme Court Limits SEC's Powers to Impose Fines." NPR, 27 June 2024, www.npr.org/2024/06/27/g-s1-2548/supreme-court-sec. Accessed 1 July 2024.
Volokh, Eugene. "Opinion: Does the Seventh Amendment Civil Jury Trial Right Apply to the States (and to Puerto Rico)?" The Washington Post, 12 Aug. 2014, www.washingtonpost.com/news/volokh-conspiracy/wp/2014/08/12/does-the-seventh-amendment-civil-jury-trial-right-apply-to-the-states-and-to-puerto-rico/. Accessed 1 July 2024.
Weiss, Paul B. "Reforming Tort Reform: Is There Substance to the Seventh Amendment?" Catholic University Law Review, vol. 38, no. 3, 1989, pp. 737–67.