jury investigation involves a public scandal. Historically, grand juries were sometimes used in American law to serve a purpose similar to an investigatory commission. Both Article III of the U.S. Constitution and the Sixth Amendment require that criminal cases be tried by a jury. Originally this applied only to federal courts. However, the Fourteenth Amendment extended this mandate to the states. Although the Constitution originally did not require a jury for civil cases, this led to an uproar which was followed by adoption of the Seventh Amendment, which requires a civil jury in cases where the value in dispute is greater than twenty dollars. However, the Seventh Amendment right to a civil jury trial does not apply in state courts, where the right to a jury is strictly a matter of state law. However, in practice, all states except Louisiana preserve the right to a jury trial in almost all civil cases where the sole remedy sought is money damages to the same extent as jury trials are permitted by the Seventh Amendment. Under the law of many states, jury trials are not allowed in small claims cases. The civil jury in the United States is a defining element of the process by which personal injury trials are handled. In practice, even though the defendant in a criminal action is entitled to a trial by jury, most criminal actions in the U.S. are resolved by plea bargain. Only about 2% of civil cases go to trial, with only about half of those trials being conducted before juries. In 1898 the Supreme Court held that the jury must be composed of at least twelve persons, although this was not necessarily extended to state civil jury trials. In 1970, however, the Supreme Court held that the twelve person requirement was a "historical accident", and upheld six-person juries if provided for under state law in both criminal and civil state court cases. There is controversy over smaller juries, with proponents arguing that they are more efficient and opponents arguing that they lead to fluctuating verdicts. In a later case, however, the court rejected the use of five-person juries in criminal cases. Juries go through a selection process called voir dire in which the lawyers question the jurors and then make "challenges for cause" and "peremptory challenges" to remove jurors. Traditionally the removal of jurors based on a peremptory challenge required no justification or