This section is from the book "Constitutional Law In The United States", by Emlin McClain. Also available from Amazon: Constitutional Law in the United States.
Constitutional provisions as to jury trial are in general applicable only to courts of general jurisdiction. Inferior courts may be provided for in which questions of fact may be tried before a jury of less than twelve, or even without a jury, the right of jury trial being sufficiently preserved in such cases if an appeal from the judgment of such a court to a court of general jurisdiction is provided for in which a jury trial may be had (Capital Traction Co. v. Hof). In limiting the requirements as to jury trial to cases where the value in controversy shall exceed twenty dollars, the intention evidently was to allow Congress to provide if it saw fit for the trial of petty cases in the federal courts without a jury; but as a matter of fact no provision is made for such trials.
 
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