preserves the "substance" of the right to jury trial. The aim of the amendment is particularly to retain the common law distinction between the province of the court and that of the jury whereby, in the absence of express or implied consent to the contrary, issues of law are to be resolved by the court and issues of fact are to be determined by the jury under appropriate instructions by the court. In Chauffeurs, Teamsters, and Helpers Local No. 391 v. Terry (1990), the Court explained that the right to a jury trial provided by the Seventh Amendment encompasses more than the common law forms of action recognized in 1791 (when the Bill of Rights was ratified), but rather any lawsuit in which parties' legal rights were to be determined, as opposed to suits that involve only equitable rights and remedies. In Galloway v. United States (1943), the Court permitted a directed verdict (a verdict ordered by a judge on the basis of overwhelming lack of evidence) in a civil suit, finding that it did not violate the Seventh Amendment under the fixed historical test. The Court extended the amendment's guarantees in Beacon Theatres v. Westover (1959) and Dairy Queen, Inc. v. Wood (1962), ruling in each case that all issues that required trial by jury under English common law also required trial by jury under the Seventh Amendment. This guarantee was also further extended to shareholder suits in Ross v. Bernhard (1970) and to copyright infringement lawsuits in Feltner v. Columbia Pictures TV (1998). In Markman v. Westview Instruments, Inc. (1996), the Court ruled that many parts of patent claims are questions of law rather than of fact, and that the Seventh Amendment guarantee of a jury trial therefore does not necessarily apply. Lawsuits against the federal government itself do not receive Seventh Amendment protections due to the doctrine of sovereign immunity. In Lehman v. Nakshian (1981), the Court ruled that "the plaintiff in an action against the United States has a right to trial by jury only where Congress has affirmatively and unambiguously granted that right by statute." Jury size The Supreme Court has held that the Seventh Amendment's guarantee of a jury trial also guarantees a jury of sufficient size. The Court found a six-member jury sufficient to meet the amendment's requirements in Colgrove v. Battin (1973). Twenty-dollars requirement Little historical evidence exists to interpret the amendment's