クラレンドン法
The origins of the blank pad rule have been traced as far back as the year 1164, when the Constitutions of Clarendon established that "[l]aymen are not to be accused save by proper and legal accusers and witnesses in the presence of the bishop". This principle was ultimately adopted by the common law tradition in England and the United States. In Thomas Jefferson's 1776 draft of the Virginia Constitution, he provided that all cases "shall be tried by a jury upon evidence given viva voce, in open court". In 1915, United States Supreme Court Justice Oliver Wendell Holmes, Jr. remarked that "[a]ny judge who has sat with juries knows that in spite of forms they are extremely likely to be impregnated by the environing atmosphere".