disputes over state boundaries and water rights, but others center on tax or interstate pollution issues. The court has tended to decline other kinds of cases arising from disputes between the states. Examples of such cases include the 1892 case of United States v. Texas, a case to determine whether a parcel of land belonged to the United States or to Texas, and Virginia v. Tennessee, a case turning on whether an incorrectly drawn boundary between two states can be changed by a state court, and whether the setting of the correct boundary requires Congressional approval. Two other original jurisdiction cases involve colonial-era borders and rights under navigable waters in New Jersey v. Delaware, and water rights between riparian states upstream of navigable waters in Kansas v. Colorado. On one occasion, United States v. Shipp, a criminal complaint was filed directly to the court, following the lynching of a defendant whose appeal to the court had been granted. The case brought against those responsible for the lynching gave the court original jurisdiction over a criminal case for the first and thus far only time in its history. Procedure Because the nine-member Supreme Court is not well-suited to conducting pretrial proceedings or trials, original jurisdiction cases accepted by the court are typically referred to a well-qualified lawyer or lower-court judge to serve as special master, conduct the proceedings, and report recommendations to the court. The court then considers whether to accept the special master's report or whether to sustain any exceptions filed to the report. Although it has not happened since 1794 in the case of Georgia v. Brailsford, parties in an action at law in which the Supreme Court has original jurisdiction may request that a jury determine issues of fact. In 1950, in the case United States v. Louisiana, the state of Louisiana moved for a jury trial, but the court denied the motion, ruling that the suit was an equity action and not an action at law, and that therefore the Seventh Amendment guarantee of a jury trial did not apply. If a matter involving an action at law did come before the court, however, a jury might be empaneled. The court noted in a footnote in the decision that under 28 U.S.C. § 1872: "In all original actions at law in the Supreme Court against citizens of the United States, issues of fact shall be tried by