Charles Starkweather and Jury nullification: Difference between pages
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'''Jury nullification''' refers to a rendering of a not guilty [[verdict]] by a trial [[jury]], disagreeing with the [[jury instruction|instructions]] by the [[judge]] concerning what is the [[law]], or whether such law is applicable to the case, taking into account all of the [[evidence (law)|evidence]] presented. Although a jury's refusal relates only to the particular case before it, if a pattern of such verdicts develops, it can have the practical effect of disabling the enforcement of that position on what is the law or how it should be applied. Juries are reluctant to render a verdict contrary to law, but a conflict may emerge between what judges and the public from whom juries are drawn hold the law to be. A succession of such verdicts may signal an unwillingness by the public to accept the law given them and may render it a "[[Dead letter#Law/Policy|dead-letter]]" or bring about its repeal. The jury system was established because it was felt that a panel of citizens, drawn at random from the community, and serving for too short a time to be corrupted, would be more likely to render a just verdict than officials who may be unduly influenced. Jury nullification is a reminder that the right to trial by one's peers<ref>[[Magna Carta]]</ref> affords the public an opportunity to take a dissenting view about the justness of a statute or official practices.
{{cquote|I consider trial by jury as the only anchor yet imagined by man by which a government can be held to the principles of its constitution.
|4=[[Thomas Jefferson]]|5=1789 letter to [[Thomas Paine]]}}
Historical examples include American revolutionaries who refused to convict under [[English law]],<ref>[http://www.gaspee.org/WhatstheImportance.html Gaspee Affair]</ref> juries who refuse to convict due to perceived injustice of a law in general,<ref>[http://tarlton.law.utexas.edu/lpop/etext/penntrial.html Trial of the Quaker William Penn (founder of Pennsylvania), 1670] and [http://www.constitution.org/trials/penn/penn-mead.htm Trial of Penn and Mead] (HTML)</ref> the perceived injustice of the way the law is applied in particular cases,<ref>[http://news.bbc.co.uk/1/hi/uk/216868.stm Clive Ponting and "Troubled history of Official Secrets Act", 1985]</ref> and cases where the juries have refused to convict due to their own [[prejudices]] such as the [[race]] of one of the [[party (law)|parties]] in the case.<ref>Kennedy, Randall. "Racial Conduct by Jurors and Judges: The Problem of the Tainted Conviction," pp. 277-282, and "Black Power in the Jury Box?", pp. 295-310, Race, Crime and the Law (1997).</ref>
==Background==
Jury nullification is a [[de facto]] power of juries, and is not normally disclosed to jurors by the system when they are instructed as to rights and duties. The power of jury nullification derives from an inherent quality of most modern [[common law]] systems—a general unwillingness to inquire into jurors' [[motivation]]s during or after [[deliberation]]s. A jury's ability to nullify the law is further supported by two common law [[precedent]]s: the prohibition on punishing jury members for their verdict, and the prohibition on retrying [[criminal law|criminal]] defendants after an [[acquittal]] (see related topic [[double jeopardy]]).
Jury nullification is the source of much debate. It is maintained that it is an important safeguard of last resort against wrongful imprisonment and government tyranny. It is also viewed as an abuse of the right to a [[jury trial]] that undermines the law and violates the [[oath]] sworn to by jurors. There are fears that nullification could be used to permit violence against socially unpopular factions. {{Fact|date=April 2007}} It can be argued that jury nullification could be used to nullify important defendants' rights, such as the [[Fifth Amendment to the United States Constitution|Fifth Amendment]] right not to testify or the right of [[self-defense]]. {{Fact|date=April 2007}} While supporters argue that jury nullification can be used only to acquit and not to convict because a [[judge]] must set aside a conviction that is clearly at odds with the law and the facts, the fact that jury verdicts are treated with great deference in United States courts means that the safeguards are not absolute and a jury that dislikes a defendant has the ability to convict an innocent defendant through nullification. Jury nullification may also occur in civil suits, in which this distinction between acquittal and conviction is of course irrelevant. {{Fact|date=April 2007}}
Nevertheless, there is little doubt as to the ability of a jury to nullify the law. Today, there are several issues raised by jury nullification.
* First, whether juries can or should be instructed or informed of their power to nullify.
* Second, whether a judge may remove jurors "for cause" when they refuse to apply the law as instructed.
* Third, whether a judge may punish a juror for exercising his power of jury nullification.
==Common law precedent==
The early history of juries supports the recognition of the ''de facto'' power of nullification. By the 12th century, common law courts began using juries for more than administrative duties. Juries were composed primarily of "laymen" from the local community. They provided a somewhat efficient means of [[dispute resolution]] with the benefit of supplying legitimacy.
Largely, the earliest juries returned verdicts in accordance with the judge or the crown. This was achieved either by "packing the jury" or by "''[[writ of attaint]]''". Juries were packed by hand-selecting or by [[bribe|bribing]] the jury so as to return the desired verdict. In cases of [[treason]] or [[sedition]], this was frequently the case. In addition, the ''writ of attaint'' allowed a judge to retry the case in front of a second jury when the judge believed the first jury returned a "false verdict". If the second jury returned a different verdict, that verdict was imposed and the first jury was imprisoned or fined.
This history, however, is marked by a number of notable exceptions. In [[1554]], a jury acquitted Sir [[Nicholas Throckmorton]], but was severely punished by the court. Almost a century later, in [[1649]], a jury likewise acquitted [[John Lilburne]] for his part in inciting a rebellion against the [[Oliver Cromwell|Cromwell]] regime. The theoretician and politician [[Eduard Bernstein]] wrote of John Lilburne's trial:
<blockquote>
His contention that the constitution of the Court was contrary to the fundamental laws of the country was unheeded, and his claim that the jury was legally entitled to judge not only as to matters of fact but also as to the application of the law itself, as the Judges represented only 'Norman intruders', whom the jury might here ignore in reaching a verdict, was described by an enraged judge as 'damnable, blasphemous heresy.' This view was not shared by the jury, which, after three days’ hearing, acquitted Lilburne — who had defended himself as skilfully as any lawyer could have done — to the great horror of the Judges and the chagrin of the majority of the Council of State. The Judges were so astonished at the verdict of the jury that they had to repeat their question before they would believe their ears, but the public which crowded the judgment hall, on the announcement of the verdict, broke out into cheers so loud and long as, according to the unanimous testimony of contemporary reporters, had never before been heard in the Guildhall. The cheering and waving of caps continued for over half an hour, while the Judges sat, turning white and red in turns, and spread thence to the masses in London and the suburbs. At night bonfires were lighted, and even during the following days the event was the occasion of joyful demonstrations.
</blockquote>
By the late 17th century, the court's ability to punish juries was removed in [[Bushell's Case]]<ref name = "Bushell's Case">[http://www.constitution.org/trials/bushell/bushell.htm Bushell's Case trial report].</ref> involving a juror on the case against [[William Penn]].
In [[1670]], [[William Penn]] was arrested for illegally preaching a [[Quaker]] sermon. Despite the fact that the judge demanded a guilty verdict and that preaching the sermon was illegal, the jury in that case acquitted Penn and was subsequently imprisoned, fined, and kept for three days without food or water as a result. Four jurors refused to pay the fine, and one, Edward Bushell, obtained a [[writ of habeas corpus]]. Chief Justice Vaughn, sitting on the highest court in England, discharged the writ, released them, and called the power to punish a jury "absurd". <ref> Simon Stern, "Between Local Knowledge and National Politics: Debating Rationales for Jury Nullification after Bushell’s Case," Yale Law Journal 111 (2002): 1815-48. </ref>
In [[1681]], a [[grand jury]] refused to [[Indictment|indict]] the [[Anthony Ashley-Cooper, 1st Earl of Shaftesbury|Earl of Shaftesbury]]. Then in [[1688]], a jury acquitted the [[Archbishop of Canterbury]] and six other [[Anglican]] bishops of [[seditious libel]].
Juries continued, even in non-criminal cases, to act in defiance of the crown. In [[1763]] and in [[1765]], juries awarded £4,000 and £300 to [[John Wilkes]] and John Entwick, respectively, in separate suits for [[trespass]] against the crown's messengers. In both cases, messengers were sent by Lord Halifax to seize allegedly [[libel|libelous]] papers.
In [[Scotland]] Jury Nullification had a profound effect bringing in (or as others believed reviving) the verdict of "[[not proven|not proven]]". It was in [[1728]] that one [[Carnegie of Finhaven]] accidentally killed the Scottish [[Charles Lyon, 6th Earl of Strathmore and Kinghorne|Earl of Strathmore]]. As the defendant had undoubtedly killed the Earl, the law (as it stood) required the jury merely to look at the facts and pass a verdict of "proven" or "[[not proven]]" depending on whether they believed the facts proved the defendant had killed the Earl. However if the jury brought in a "proven" verdict they would in effect cause this innocent man to die. To avert this injustice, the jury decided to assert what it believed to be their "ancient right" to judge the whole case and not just the facts and brought in the verdict of "not guilty" which remains in Scotland to this day. Over time however, juries have tended to favour the "not guilty" verdict over the "not proven" and with this the interpretation has changed {{Fact|date=July 2007}}. Now the "not guilty" verdict has become the normal verdict when a jury is convinced of innocence and the "not proven" verdict is only used when the jury is not certain of innocence or guilt.
==Nullification in the United States==
[[John Peter Zenger]], a printer in the English colony of New York, was tried for [[seditious libel]] in [[1734]] for publishing a newspaper critical of the governor. The jury acquitted Zenger despite the judge's instructions; this is perhaps the most famous early instance of jury nullification in the colonies that became the United States.
The use of the jury to act as a protection of last resort was espoused by many influential people surrounding the framing of the [[U.S. Constitution]]. For example, [[John Adams]] said of jurors: "It is not only his right but also his duty… to find the verdict according to his own best understanding, judgment, and conscience, though in direct opposition to the direction of the court."
First Chief Justice of the US [[John Jay]] wrote: "It is presumed, that juries are the best judges of facts; it is, on the other hand, presumed that courts are the best judges of law. But still both objects are within your power of decision… you [juries] have a '''right''' to take it upon yourselves to judge of both, and to determine the law as well as the fact in controversy".
It was over time that judicial and legal opinion slowly changed to consider jury nullification only a power and not a right of juries, as judges and prosecutors wanted stricter enforcement of laws that juries nullified. This shift stemmed from the 18th century conflict between two factions of English jurists, the first led by [[Charles Pratt, 1st Earl Camden|Lord Camden]], which was originally prevalent in what became the United States, and the second led by [[William Murray, 1st Earl of Mansfield and Mansfield|Lord Mansfield]]. The position of the latter was called "Mansfieldism" by Jefferson<ref>[http://www.constitution.org/tj/ltr/1826/ltr_18260217_madison.htm Letter to James Madison, February 17, 1826], complaining of Mansfieldism</ref> and the shift has been called "Mansfieldization".<ref>[http://www.constitution.org/lrev/jdr/mansfield_recon.htm Mansfieldism Reconsidered], by Jon Roland</ref>
===Nullification in practice===
Nullification has a mixed history in the United States. Jury nullification appeared in the pre-Civil War era when juries occasionally refused to convict for violations of the [[Fugitive Slave Act]]. However, during the Civil Rights era, all-white juries were known to refuse to convict white defendants for the murder of African-Americans.<ref name = "Cato">[http://www.cato.org/pubs/policy_report/v21n1/jury.html Cato].</ref> During [[Prohibition]], juries often nullified alcohol control laws,<ref name = "UMKC">[http://www.law.umkc.edu/faculty/projects/ftrials/zenger/nullification.html UMKC].</ref> possibly as often as 60% of the time.<ref name = "FIJA">[http://www.fija.org/conrad_on_jury_duty.htm Conrad on Jury Duty].</ref> This resistance is considered to have contributed to the adoption of the [[Twenty-first Amendment to the United States Constitution|Twenty-first amendment]] repealing the [[Eighteenth_Amendment_to_the_United_States_Constitution|Eighteenth amendment]] which established [[Prohibition]].
In the 21st century, many discussions of jury nullification center around drug laws that some consider unjust either in principle or because they are seen to discriminate against African-Americans. A jury nullification advocacy group estimates that 3–4% of all jury trials involve nullification,<ref name = "FIJA" /> and a recent rise in [[hung jury|hung juries]] (from an average of 5% to nearly 20% in recent years) is considered additional evidence that juries have begun to consider the validity or fairness of the laws themselves.<ref name = "WashPost">[http://www.washingtonpost.com/wp-srv/national/jury080299.htm Washington Post].</ref>
In criminal cases, jury nullification arguments sometimes focus on the precise language of the [[jury instruction]] on the [[burden of proof]]. Many jury instructions on the issue of the burden of proof invite nullification arguments. According to these instructions juries ''must'' find the defendant not guilty if the case has not been proven beyond a reasonable doubt. Conversely the jury ''should'' find the defendant guilty if the case has been proven beyond a reasonable doubt. The permissive language "should" arguably allows juries to consider nullification arguments.
===Court rulings===
In recent years, judges seem to like jury nullification less and less. While unable to take away the power of nullification, they have done much to prevent its use.
The first major decision in this line was ''Games v. Stiles ex dem Dunn'', 39 U.S. 322 (1840),<ref>[http://www.constitution.org/ussc/039-322.htm Games v. Stiles ex dem Dunn]</ref> which held that the bench could override the verdict of the jury on a point of law.
The [[1895]] decision in ''[[Sparf v. U.S.]]'' written by Justice [[John Marshall Harlan]] held that a trial judge has no responsibility to inform the jury of the right to nullify laws. It was a 5-4 decision. This decision, often cited, has led to a common practice by [[United States]] judges to penalize anyone who attempts to present legal argument to jurors and to declare a mistrial if such argument has been presented to them. Jurors are likely to be struck from the panel during [[voir dire]] if they reveal awareness of the concept of jury nullification.<ref>"...the court can also attempt to prevent such an occurrence of juror nullification by (1) informing prospective jurors at the outset that jurors have no authority to disregard the law and (2) obtaining their assurance that they will not do so if chosen to serve on the jury." ''People v. Estrada'', 06 S.O.S. 3702 (2006).</ref>
A [[1969]] [[Fourth Circuit Court of Appeals|Fourth Circuit]] decision, ''[[U.S. v. Moylan]]'', affirmed the right of jury nullification, but also upheld the power of the court to refuse to permit an instruction to the jury to this effect.
<blockquote>
We recognize, as appellants urge, the undisputed power of the jury to acquit, even if its verdict is contrary to the law as given by the judge, and contrary to the evidence. This is a power that must exist as long as we adhere to the general verdict in criminal cases, for the courts cannot search the minds of the jurors to find the basis upon which they judge. If the jury feels that the law under which the defendant is accused, is unjust, or that exigent circumstances justified the actions of the accused, or for any reason which appeals to their logic or passion, the jury has the power to acquit, and the courts must abide by that decision. ''U.S. vs Moylan'', 417 F 2d 1002, 1006 (1969).[http://www.askthelawguy.info/images/moylan.pdf]
</blockquote>
Nevertheless, in upholding the refusal to permit the jury to be so instructed, the Court held that:
<blockquote>
…by clearly stating to the jury that they may disregard the law, telling them that they may decide according to their prejudices or consciences (for there is no check to insure that the judgment is based upon conscience rather than prejudice), we would indeed be negating the rule of law in favor of the rule of lawlessness. This should not be allowed. ''Id.''
</blockquote>
In [[1972]], in ''[[United States v. Dougherty]]'', [[case citation|473 F.2d 1113]], the [[United States Court of Appeals for the District of Columbia Circuit]] issued a ruling similar to ''Moylan'' that affirmed the ''de facto'' power of a jury to nullify the law but upheld the denial of the defense's chance to instruct the jury about the power to nullify. However, in ''Dougherty'' the then-chief judge [[David L. Bazelon]] authored a dissenting in part opinion, arguing that the jury should be instructed about their power to render the verdict according to their conscience if the law was unjust. He wrote that refusal to allow the jury to be instructed constitutes a "deliberate lack of candor".<ref> [http://www.law.umkc.edu/faculty/projects/ftrials/juryseminar/USvDougherty1972.html U.S. v Dougherty] </ref>
In [[1988]], in ''U.S. v. Krzyske'', the jury asked the judge about jury nullification. The judge responded "There is no such thing as valid jury nullification." The jury convicted the defendant, and the judge's answer was upheld on appeal.
In [[1997]], in ''U.S. v. Thomas''<ref>[http://caselaw.lp.findlaw.com/scripts/getcase.pl?court=2nd&navby=case&no=951337 U.S. v. Thomas No. 95-1337 (2nd Cir. 5-20-97).]</ref>, the Second Circuit ruled that jurors can be removed if there is evidence that they intend to nullify the law, under Federal Rules of Criminal Procedure 23(b).
<blockquote>
We categorically reject the idea that, in a society committed to the rule of law, jury nullification is desirable or that courts may permit it to occur when it is within their authority to prevent. Accordingly, we conclude that a juror who intends to nullify the applicable law is no less subject to dismissal than is a juror who disregards the court's instructions due to an event or relationship that renders him biased or otherwise unable to render a fair and impartial verdict.
</blockquote>
In [[2001]], a California Supreme Court ruling on a case involving [[statutory rape]] led to a new jury instruction that requires jurors to inform the judge whenever a fellow panelist appears to be deciding a case based on his or her dislike of a law.<ref name = "SMC">{{cite news|url=http://homepage.smc.edu/sindell_steven/AJ3%20Folder/Currentevents/aj3.jury.nullific.html|title=Justices Say Jurors May Not Vote Conscience|work=[[SMC]]|date=2001-05-08|accessdate=2006-12-17}}</ref> However, the ruling could not overturn the practice of jury nullification itself because of double jeopardy: a defendant who has been acquitted of a charge cannot be charged a second time with it, even if the court later learns jury nullification played a role in the verdict.
Although the Supreme Court has not directly confronted the issue recently, dicta in several opinions by Justice [[Antonin Scalia]] seems to imply a strong belief in the importance of the jury, in which the potential for nullification might be thought implicit; juries, Scalia has argued, are "the spinal column of American democracy," ''[[Neder v. United States]]'', "function as circuitbreaker[s] in the State’s machinery of justice," ''[[Blakely v. Washington]],'' and while trial by jury "has never been efficient… it has always been free," ''[[Apprendi v. New Jersey]]''.
===Advocacy groups===
Some advocacy groups and websites such as the:
* [[Fully Informed Jury Association]]
* [http://www.levellers.org/jrp The Jury Rights Project]
* [http://www.jurypower.org The Jury Education Committee ]
argue that private parties in cases where the government is the opponent have the right to have juries be instructed that they have the right and duty to render a verdict contrary to legal positions they believe to be unjust or unconstitutional. These and other organizations contact citizens directly and lobby for legal reforms regarding instructions given to jurors.
* [http://www.constitution.org/jury/pj/pj-us.htm Constitution Society] Presents historical documentation that supports the proposition that to be a lawful jury trial, all issues of law must be argued in the presence of the jury, with the exception of those that cannot be argued without revealing evidence that is properly excluded.
===Opponents===
A notable opponent of jury nullification is former judge and unsuccessful Supreme Court nominee [[Robert Bork]]. In an essay he wrote jury nullification is a "pernicious practice".<ref> [http://www.leaderu.com/ftissues/ft9906/articles/bork.html Thomas More for Our Season] Robert H. Bork </ref>
==Nullification in Canada==
Although very rare, nullification does occur in Canada, however the Crown (prosecution) has a broader power to appeal rulings than in the US. So while a jury ''may'' ignore a judge's direction, Canadian law allows the prosecution to appeal from an acquittal (see also [[Double jeopardy]]). The often referenced case of jury nullification being appealed all the way to the country's highest court in Canada is the 1988 Supreme Court case, ''[[R. v. Morgentaler]], 1988 SCR 30'' [http://scc.lexum.umontreal.ca/en/1988/1988rcs1-30/1988rcs1-30.html].
In addition, the Supreme Court of Canada, in a more recent decision ''R. v. Krieger 2006 SCC 47'' [http://scc.lexum.umontreal.ca/en/2006/2006scc47/2006scc47.html], confirmed that juries in Canada have the power to refuse to apply the law when their consciences require that they do so. The issue was also touched upon in ''R. v. Latimer, 2001 SCC 1'' [http://scc.lexum.umontreal.ca/en/2001/2001scc1/2001scc1.html], where "The trial did not become unfair simply because the trial judge undermined the jury’s de facto power to nullify. In most if not all cases, jury nullification will not be a valid factor in analyzing trial fairness for the accused. Guarding against jury nullification is a desirable and legitimate exercise for a trial judge; in fact a judge is required to take steps to ensure that the jury will apply the law properly."
==Nullification in the UK==
In 1982, during the [[Falklands War]], the British Navy sunk an Argentine Cruiser – the “[[ARA General Belgrano]]”. A government employee (civil servant) named [[Clive Ponting]] leaked two government documents concerning the sinking of the cruiser to the press, and was subsequently charged with breaching the [[Official Secrets Act]]. The judge in the case directed the jury to convict Ponting as he had clearly broken the Official Secrets Act by leaking official information about the sinking of the Belgrano during the Falklands War. His main defence, that it was in the public interest that this information be made available, was not a defence at all in law, but the jury nevertheless acquitted him, much to the consternation of the Government. He had argued that he had acted out of 'his duty to the interests of the state'; the judge had argued that [[civil servants]] owed their duty to the government.
==Nullification in popular fiction==
On the American [[legal drama]] ''[[Law & Order]]'', in the eighth season episode "Nullification," the members of a [[Christian Patriot]] [[Militia_%28United_States%29#Modern_Private_Militia_organizations|militia]] are indicted for [[murder]] and [[robbery|armed robbery]] for their role in the attempted [[hijacking]] of an [[armored car]]. At trial, the leader of the militia ([[Denis O'Hare]]), who represents the group ''[[pro se]]'', argues that they are fighting a [[war]] against the illegitimate government of the United States, and that therefore the [[defendant]]s are [[prisoner of war|prisoners of war]] unlawfully detained in violation of the [[Geneva Conventions]]. In his [[testimony]], and later in his [[closing argument]], he explicitly argues in favor of jury nullification in the case as a blow against the "[[New World Order (conspiracy)|New World Order]]" and government tyranny. Although the prosecution manages to disqualify and replace two jurors who express sympathy with the militia cause, the trial ends in a [[hung jury]], as one or more jurors agree with the argument in favor of nullification.
Although that is the only time that ''Law & Order'' specifically addresses the issue of jury nullification, it has occurred in other episodes. In the eighth season episode "Burden," for example, a jury, deprived of evidence demonstrating the work of a [[serial killer]], votes to acquit an [[narcissism|egomaniacal]] [[physician]] ([[John Hickock]]) who claims that the death of a young boy in a [[persistent vegetative state]] was an act of [[euthanasia]]. Later, in the eleventh season episode "Standoff," a jury acquits a [[corrections officer]] ([[Matt Mulhern]]) who hired a [[contract killing|contract killer]] to eliminate his fiancee's [[rape|rapist]].
On the legal drama ''[[The Practice]]'', which follows criminal trials from the [[Defense (legal)|defense attorney]]'s perspective, the characters use jury nullification on a fairly regular basis, especially when they defend clients accused of so-called [[victimless crime]]s such as [[prostitution]], [[bookmaking]], or [[drug possession]]. The strategy usually used in such situations, known as "This Is America" to its practitioners, was essentially an appeal to [[patriotism]].
During the first season of the show, a multi-episode [[story arc]] concerns the defense of a grieving father ([[Jack Laufer]]) who murdered his daughter's recently-[[acquittal|acquitted]] killer ([[Greg Wrangler]]). Although the official defense is [[diminished responsibility]], it amounts to a pitch for jury nullification, given overwhelming evidence of [[premeditation]]. After a prosecution spanning four episodes, the defendant is acquitted on all charges.
==See also==
* [[Death-qualified jury]]
* [[Jury duty]]
* [[Laura Kriho]]
* [[Ed Rosenthal]]
* [[Josephine Terranova]]
* [[Peter Wright]]
* [[John Peter Zenger]]
* ''[[Citizens Rule Book]]''
== References ==
Eduard Bernstein, ''Sozialismus und Demokratie in der grossen englischen Revolution'' (1895); trans. H.J.Stenning (1963, NYC) as ''Cromwell and Communism: Socialism and Democracy in the Great English Revolution'', Library of Congress 63-18392.
<references/>
==External links==
* [http://www.marx.org/reference/archive/bernstein/works/1895/cromwell/index.htm ''"Cromwell and Communism"'' aka ''Socialism and Democracy in the Great English Revolution'']
* [http://www.law.umkc.edu/faculty/projects/ftrials/zenger/nullification.html ''Jury Nullification'' by Doug Linder]
* [http://www.greenmac.com/eagle/ISSUES/ISSUE23-9/07JuryNullification.html ''Jury Nullification: Why you should know what it is'' by Russ Emal]
* [http://www.caught.net/juror.htm ''Juror's Handbook - A Citizen's Guide to Jury Duty'' by the American Jury Institute]
* [http://www.gutenberg.org/catalog/world/readfile?fk_files=38730&pageno=1 ''Essay on the Trial by Jury''] by [[Lysander Spooner]]
* [http://www.fija.org ''FIJA''] - Fully Informed Jury Association
[[Category:Court systems]]
[[Category:Criminal law]]
[[he:ביטול על ידי מושבעים]]
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