Colonial Americans had frequently experienced the disadvantages faced by those accused of crimes under English law. Therefore, as early as the Massachusetts Body of Liberties in 1641, they protected the right to a speedy trial, by a jury, and with counsel. After independence, many states also protected such rights in their constitutions. The Sixth Amendment was added to the U.S. Constitution to ensure that criminal defendants received a fair trial—although it does not use those exact words. The amendment repeats Article III’s guarantee of a trial by jury in criminal cases, but it adds other important rights as well—such as the right to subpoena witnesses and to have a lawyer. The Sixth Amendment attempts to balance the enormous power of the state, which pays for both police and prosecutors to prove guilt, against the power of the individual to prove innocence.