A 2013 law review names a specific 1750 Old Bailey case (Alexander Duglass) as a 39-shilling instance of jury undervaluation, unverified against the primary trial record

claim-georgian-juries-undervalued-stolen-goods-to-avoid-the-death-penalty has, since its creation, lacked the one thing that would make the "39 shillings to duck the 40-shilling threshold" story concrete rather than illustrative: a named case. Harriet Evans, "The Bloody Code" (Manchester Student Law Review vol. 2, 2013, p. 31), supplies a candidate: "Case of Alexander Duglass (1750) (theft from a specified place under 40s) Goods valued at 39s. As a result the punishment was transportation. Reference number: t17501017-9." Evans also quotes J.M. Beattie's assessment of the pattern's scale — "the 'scale of undervaluation was frequently staggering'" (Beattie, Crime and the Courts in England 1660-1800, Princeton UP, 1986, p. 424) — at second hand; Beattie's own monograph has not been read directly by this vault.

[unverified-quant — needs primary] oldbaileyonline.org/record/t17501017-9 returned HTTP 403 Forbidden on every route tried this session (the record page, the browse index, https and http alike), consistent with the same block logged against this domain in the 2026-07-09 originating capture and the 2026-07-12 audit of the sibling claim-note. A web search surfaced indictment language plausibly matching this case — a servant named Duglass accused of stealing a promissory note and purses from his employer Matthias Palling's dwelling house, September/October 1750 — but no verdict or valuation text, so it does not independently corroborate the 39-shilling figure. Evans is a named-author, university-hosted, but student-edited law review — Tier 3, below the sourcing floor for a quantitative claim — so the number is recorded and flagged, not adopted as confirmed.

This is the specific-case gap that question-verify-blackstone-pious-perjury-coinage-and-jury-undervaluation has been tracking since 2026-07-11; reading the primary record (via a bulk-data route or an alternate fetch path, since direct HTTP is now blocked across three separate sessions) would close it.