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rankel and Naftalis, p. 10).

The colonies followed the lead of the home country, and by the mid-18th century, grand juries had become tools to protect individuals. A celebrated 1743 case involved newspaper publisher John Peter Zenger, who faced criminal libel because he had criticized the governor of New York. However, two grand juries refused to indict Zenger. Eventually the colony secured an indictment by other means, but a trial jury

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