esquires, or persons of higher degree. The special jury was eliminated in 1949, excepting the City of London special jury that remained available until 1971 for commercial trials in the King's Bench Division of the High Court of Justice. The last case using a special jury occurred in London in 1950. The jury de medietate linguae were abolished in the Naturalization Act 1870, which also gave foreigners the right to serve on juries. United States This method may be used in many U.S. states. In some states it may be used for both criminal and civil cases, in other states for only one of the two kinds. In at least the state of Washington, it is the default method of choosing a jury. Some courts of appeals in the U.S. have determined that a struck jury offers greater opportunity to shape the final jury than the more common "sequential" (also known as "strike and replace" or "jury box") method, where peremptory challenges can only be issued against those jurors already seated, with no knowledge of the replacement. The use of this system in murder cases, when properly enabled by statute, was held by the Supreme Court of the United States to be constitutional in Brown v. New Jersey, . Some methods of implementing a struck jury have handled waived challenges by eliminating the last identified member of the juror pool. In discrimination cases, this has been treated as identical to specifically challenging that juror. As a result, the now preferred method of handling waived challenges is to let the other side finish its challenges and then randomly eliminate jurors to get to the number needed. New Zealand In New Zealand, the special jury has become obsolete and is no longer used. The need to provide special expertise through selection of jurors was eliminated by the introduction of expert witnesses, expert advisors to the judge, and administrative tribunals. The jury de medietate linguae from English common law was used for cases where a Māori was accused of a crime until it was abolished in 1961. Major or famous cases King v. Zenger, 1735 In 1735, John Peter Zenger, a newspaper publisher, was arrested and tried for libel against the governor of New York, which was then a colony of England. His first two lawyers were disbarred for attempting to turn the trial into an indictment of the governor. The judge appointed