reference to "twenty dollars", which was added in a closed session of the Senate and is often omitted in judicial and scholarly discussion of the amendment. A Harvard Law Review article described it as "mysterious... of shrouded origin and neglected for two centuries", stating that "no one believes that the Clause bears on the right protected by the Seventh Amendment". According to law professor Philip Hamburger, the twenty-dollar requirement was intended to become obsolete by inflation, so that its application to more cases would be phased out gradually. $20 in 1800 is . Congress has never extended federal diversity jurisdiction to amounts that small. Under federal law (28 U.S.C. §1332), the amount in dispute must exceed $75,000 for a case to be heard in federal court based on diversity of the parties' citizenship (the parties are from different states or different countries). However, civil cases may arise in federal court that are not diversity cases (e.g., in places like the District of Columbia that are federal jurisdictions), in which case the Twenty Dollars Clause may apply. Re-examination of facts The Re-Examination Clause of the Seventh Amendment states: "In suits at common law,... no fact tried by jury, shall be otherwise reexamined in any Court of the United States, than according to the rules of the common law." This clause forbids any court from re-examining or overturning any factual determinations made by a jury guaranteeing that facts decided by that jury cannot be reexamined at a later date. Exceptions to this prohibition are possible if it is later determined that legal errors were made or evidence submitted was insufficient in some way. In such cases the re-examination is conducted by another jury so the decision is still left in the hands of the people. The clause applies only to cases where private rights—i.e., rights that exist between private citizens—have been violated. The Re-Examination Clause applies not only to federal courts, but also to "a case tried before a jury in a state court and brought to the Supreme Court on appeal". In The Justices v. Murray, 76 U.S. 9 Wall. 274 (1869), the Supreme Court quoted Justice Joseph Story to explain the modes to reexamine facts tried by juries according to common law: "Mr. Justice Story ... referring to this part of the amendment, observed ... that it was 'a prohibition to the courts of the United States to re-examine any