trial and from cruel and unusual punishment. He concludes that in all cases these rights were insufficiently or not at all protected in late-eighteenth-century England. Libel laws were vigorously enforced, so that anyone who criticized the government was subject to prosecution for sedition. Free association was restricted, as the turbulent history of the Chartist movement demonstrates. Freedom of religion was absent, and due process in the terms of the Fifth Amendment was inconsistent with the supremacy of the parliamentary system. It was, however, in criminal law that the progressive nature of the Bill of the Rights was most manifest. Even when English law recognized similar rights, they did not have the status they have assumed in the American system.
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This is due in significant part to the fact that England lacked a written constitution, including a bill of rights, enforceable by the courts against abridgement by Parliament, the Crown, and the common law. The English Bill of Rights of 1689 was hortatory, possessing only the status of a statute. What was "ought not" in the British system became "shall not" in the American. Grammar matters: much depends on whether the mood of the verb is subjunctive ("you may") or imperative (''you must").
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Others, however, see a closer connection at least between the Constitution and Magna Carta, especially as interpreted by Sir Edward Coke, with whose works the framers were widely familiar. "Both were written documents," observes A. E. Dick Howard, "both were born of times of crisis in which men believed tyrannical rulers to be threatening their liberties, both were seen by eighteenth-century Americans as embodying natural rights, beyond the reach of positive law." 23 Both, too, were practical solutions to real and urgently felt issues of their times.
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Statistically, the Bill of Rights is an American innovation. The ten amendments contain a total of twenty-seven separate rights. Only six of these, or about 20 percent, were first stated in Magna Carta. Twenty-one, or about 75 percent, had already been formulated in colonial documents written before the 1689 English Bill of Rights. Only the Ninth Amendment could not be found in several
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