Question: When did the people who won the Battle of Saratoga in the Revolutionary War really begin to establish their own laws independent of the English?

full_context: Document 1: Rule of law: In 1776, the notion that no one is above the law was popular during the founding of the United States. For example, Thomas Paine wrote in his pamphlet Common Sense that ``in America, the law is king. For as in absolute governments the King is law, so in free countries the law ought to be king; and there ought to be no other. ''In 1780, John Adams enshrined this principle in the Massachusetts Constitution by seeking to establish`` a government of laws and not of men.''
Document 2: Law of the United States: Unlike the situation with the states, there is no plenary reception statute at the federal level that continued the common law and thereby granted federal courts the power to formulate legal precedent like their English predecessors. Federal courts are solely creatures of the federal Constitution and the federal Judiciary Acts. However, it is universally accepted that the Founding Fathers of the United States, by vesting "judicial power" into the Supreme Court and the inferior federal courts in Article Three of the United States Constitution, thereby vested in them the implied judicial power of common law courts to formulate persuasive precedent; this power was widely accepted, understood, and recognized by the Founding Fathers at the time the Constitution was ratified. Several legal scholars have argued that the federal judicial power to decide "cases or controversies" necessarily includes the power to decide the precedential effect of those cases and controversies.
Document 3: France in the American Revolutionary War: The British had taken Philadelphia in 1777, but American victory at the Battle of Saratoga brought back hope to the Patriots and enthusiasm in France. The army of Burgoyne surrendered to American forces after Saratoga and France realized that the United States could be victorious. The king directed Vergennes to negotiate an alliance with the Americans.
Document 4: Law of the United States: As federal judge Alex Kozinski has pointed out, binding precedent as we know it today simply did not exist at the time the Constitution was framed. Judicial decisions were not consistently, accurately, and faithfully reported on both sides of the Atlantic (reporters often simply rewrote or failed to publish decisions which they disliked), and the United Kingdom lacked a coherent court hierarchy prior to the end of the 19th century. Furthermore, English judges in the eighteenth century subscribed to now-obsolete natural law theories of law, by which law was believed to have an existence independent of what individual judges said. Judges saw themselves as merely declaring the law which had always theoretically existed, and not as making the law. Therefore, a judge could reject another judge's opinion as simply an incorrect statement of the law, in the way that scientists regularly reject each other's conclusions as incorrect statements of the laws of science.
Document 5: United States: The original text of the Constitution establishes the structure and responsibilities of the federal government and its relationship with the individual states. Article One protects the right to the "great writ" of habeas corpus. The Constitution has been amended 27 times; the first ten amendments, which make up the Bill of Rights, and the Fourteenth Amendment form the central basis of Americans' individual rights. All laws and governmental procedures are subject to judicial review and any law ruled by the courts to be in violation of the Constitution is voided. The principle of judicial review, not explicitly mentioned in the Constitution, was established by the Supreme Court in Marbury v. Madison (1803) in a decision handed down by Chief Justice John Marshall.
Document 6: Battles of Saratoga: The Battles of Saratoga (September 19 and October 7, 1777) marked the climax of the Saratoga campaign, giving a decisive victory to the Americans over the British in the American Revolutionary War. British General John Burgoyne led a large invasion army southward from Canada in the Champlain Valley, hoping to meet a similar British force marching northward from New York City and another British force marching eastward from Lake Ontario; the southern and western forces never arrived, and Burgoyne was surrounded by American forces in upstate New York. He fought two small battles to break out which took place 18 days apart on the same ground, 9 miles (14 km) south of Saratoga, New York. They both failed.
Document 7: Law of the United States: Early on, American courts, even after the Revolution, often did cite contemporary English cases. This was because appellate decisions from many American courts were not regularly reported until the mid-19th century; lawyers and judges, as creatures of habit, used English legal materials to fill the gap. But citations to English decisions gradually disappeared during the 19th century as American courts developed their own principles to resolve the legal problems of the American people. The number of published volumes of American reports soared from eighteen in 1810 to over 8,000 by 1910. By 1879 one of the delegates to the California constitutional convention was already complaining: "Now, when we require them to state the reasons for a decision, we do not mean they shall write a hundred pages of detail. We [do] not mean that they shall include the small cases, and impose on the country all this fine judicial literature, for the Lord knows we have got enough of that already."
Document 8: Battles of Saratoga: Burgoyne found himself trapped by superior American forces with no relief in sight, so he retreated to Saratoga (now Schuylerville) and surrendered his entire army there on October 17. His surrender, says historian Edmund Morgan, ``was a great turning point of the war because it won for Americans the foreign assistance which was the last element needed for victory. ''
Document 9: Procedures of the Supreme Court of the United States: Thereafter, if the Court chooses to hold a hearing, each side has thirty minutes to present its case orally. In exceptional and controversial cases, however, the time limit may be extended. In the Court's early years, attorneys might argue a single case for hours or even days; but as the judicial workload increased, the time available for argument has been restricted. The late Chief Justice Rehnquist was noted for his especially strict enforcement of the argument time limits.
Document 10: Battles of Saratoga: Once news of Burgoyne's surrender reached France, King Louis XVI decided to enter into negotiations with the Americans that resulted in a formal Franco - American alliance and French entry into the war. This moved the conflict onto a global stage. As a consequence, Britain was forced to divert resources used to fight the war in North America to theaters in the West Indies and Europe, and rely on what turned out to be the chimera of Loyalist support in its North American operations. Being defeated by the British in the French and Indian War more than a decade earlier, France found an opportunity of revenge by aiding the colonists throughout the Revolutionary War. Prior to the Battle of Saratoga, France did n't fully aid the colonists. However, after the Battles of Saratoga were conclusively won by the colonists, France realized that the Americans had the hope of winning the war, and began fully aiding the colonists by sending soldiers, donations, loans, military arms, and supplies.
Document 11: English law: Since 1189, English law has been described as a common law rather than a civil law system; in other words, no comprehensive codification of the law has taken place and judicial precedents are binding as opposed to persuasive. This may be a legacy of the Norman conquest of England, when a number of legal concepts and institutions from Norman law were introduced to England. In the early centuries of English common law, the justices and judges were responsible for adapting the system of writs to meet everyday needs, applying a mixture of precedent and common sense to build up a body of internally consistent law. An example is the Law Merchant derived from the ``Pie - Powder ''Courts, named from a corruption of the French pieds - poudrés (`` dusty feet'') implying ad hoc marketplace courts. As the Parliament of England became ever more established and influential, legislation gradually overtook judicial law - making such that today, judges are only able to innovate in certain very narrowly defined areas.
Document 12: Supreme Court of the United States: Article III of the United States Constitution does not specify the number of justices. The Judiciary Act of 1789 called for the appointment of six ``judges ''. Although an 1801 act would have reduced the size of the court to five members upon its next vacancy, an 1802 act promptly negated the 1801 act, legally restoring the court's size to six members before any such vacancy occurred. As the nation's boundaries grew, Congress added justices to correspond with the growing number of judicial circuits: seven in 1807, nine in 1837, and ten in 1863.
Document 13: John Burgoyne: John Burgoyne is best known for his role in the American Revolutionary War. He designed an invasion scheme and was appointed to command a force moving south from Canada to split away New England and end the rebellion. Burgoyne advanced from Canada but his slow movement allowed the Americans to concentrate their forces. Instead of coming to his aid according to the overall plan, the British Army in New York City moved south to capture Philadelphia. Surrounded, Burgoyne fought two small battles near Saratoga to break out. Trapped by superior American forces, with no relief in sight, Burgoyne surrendered his entire army of 6,200 men on 17 October 1777. His surrender, says historian Edmund Morgan, "was a great turning point of the war, because it won for Americans the foreign assistance which was the last element needed for victory". He and his officers returned to England; the enlisted men became prisoners of war. Burgoyne came under sharp criticism when he returned to London, and never held another active command.
Document 14: Battles of Saratoga: Burgoyne's strategy to divide New England from the southern colonies had started well but slowed due to logistical problems. He won a small tactical victory over General Horatio Gates and the Continental Army in the September 19 Battle of Freeman's Farm at the cost of significant casualties. His gains were erased when he again attacked the Americans in the October 7 Battle of Bemis Heights and the Americans captured a portion of the British defenses. Burgoyne was therefore compelled to retreat, and his army was surrounded by the much larger American force at Saratoga, forcing him to surrender on October 17. News of Burgoyne's surrender was instrumental in formally bringing France into the war as an American ally, although it had previously given supplies, ammunition, and guns, notably the de Valliere cannon which played an important role in Saratoga. This battle also resulted in Spain joining France in the war against Britain.
Document 15: American Revolution: The Continental Army forced the British out of Boston in 1776, but the British captured and held New York City for the duration of the war. The British blockaded ports and captured other cities for brief periods, but they failed to defeat Washington's forces. The Patriots unsuccessfully attempted to invade Canada during the winter of 1775 -- 76, but they captured a British army at the Battle of Saratoga in late 1777, and the French entered the war as allies of the United States as a result. The war later turned to the American South where the British under the leadership of Charles Cornwallis captured an army at South Carolina but failed to enlist enough volunteers from Loyalist civilians to take effective control of the territory. A combined American -- French force captured a second British army at Yorktown in 1781, effectively ending the war in the United States. The Treaty of Paris in 1783 formally ended the conflict, confirming the new nation's complete separation from the British Empire. The United States took possession of nearly all the territory east of the Mississippi River and south of the Great Lakes, with the British retaining control of Canada and Spain taking Florida.
ground_truth: mid-19th century
sub_queries: who won the battle of saratoga in the revolutionary war Answer: Americans
When did Americans really begin to establish their own laws independent of the English? Answer: mid-19th century