Sturges v. Crowninshield
4 Wheat. 122 (1819)
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Rule of Law:
The Seventh Amendment right to a trial by jury in a civil case can be voluntarily waived by a party through a prior contractual agreement. A statute providing for a summary collection process does not violate this right, provided the party has an opportunity to contest the claim and demand a jury trial.
Facts:
- The Maryland legislature passed an act incorporating the Bank of Columbia.
- The act of incorporation provided a 'summary remedy' allowing the bank to collect on certain defaulted notes without a pre-judgment trial.
- Okely signed a promissory note that was made 'expressly negotiable at the Bank of Columbia.'
- By executing this specific type of note, Okely agreed to be subject to the summary collection procedures outlined in the bank's charter.
- Okely subsequently defaulted on his payment obligation under the note.
Procedural Posture:
- The Bank of Columbia initiated a summary proceeding against Okely in the District of Columbia under its charter.
- The president of the bank applied to the clerk of the court for an execution against Okely's property for the defaulted note.
- Okely challenged the execution in the Circuit Court for the District of Columbia, arguing the underlying Maryland statute authorizing the procedure was unconstitutional.
- The Circuit Court ruled in favor of Okely, quashing the execution.
- The Bank of Columbia, as appellant, brought the case to the U.S. Supreme Court on a writ of error.
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Issue:
Does a Maryland statute that authorizes a bank to obtain an execution against a debtor without a prior court judgment, based on a promissory note the debtor voluntarily made negotiable at the bank, violate the debtor's Seventh Amendment right to a jury trial?
Opinions:
Majority - Justice Johnson
No. The Maryland statute does not violate the Seventh Amendment because the right to a jury trial can be relinquished by voluntary consent. By making the note negotiable at the Bank of Columbia, Okely chose his own jurisdiction and, in consideration for the credit extended to him, voluntarily waived his right to the ordinary administration of justice. The Seventh Amendment preserves the 'right' of trial by jury, which implies it can be waived, unlike a mandatory command. Furthermore, the process is not a total prostration of this right, as the statute allows the debtor to have an issue made up and a trial by jury if he disputes the justice of the claim. The 'law of the land' provision from Magna Charta, incorporated into Maryland's constitution, is intended to protect individuals from arbitrary government power, not from the consequences of their own voluntary agreements.
Analysis:
This decision establishes the key principle that the Seventh Amendment right to a jury trial in civil cases is a personal right that can be contractually waived. It reinforces the concept of party autonomy, allowing individuals and entities to agree to alternative and more expeditious dispute resolution mechanisms. This precedent provides a constitutional foundation for the enforcement of various contractual provisions that alter standard litigation procedures, such as arbitration clauses and cognovit notes, so long as the waiver is voluntary and the process is not fundamentally unjust.
