The prohibition of overturning a jury's verdict applies to federal cases, state cases involving federal law, and to review of state cases by federal courts. "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 lawsuit. The amendment thus does not guarantee trial by jury in cases under maritime law, in lawsuits against the government itself, and for many parts of patent claims. In all other cases, the jury can be waived by consent of the parties. The amendment also guarantees a minimum of six members for a jury in a civil trial. 