Refuting the argument that anonymous juries are barred by the Public Trial Clause where a proposed version of the Amendment which would have imported the traditional common law requirement of jury identification was rejected in 1789 and, instead, jury identification requirements were administered through statute. Arguing that, while the Framers and Founding-Era scholarship discussed “reputational accountability,” this concern was directed at judges and witnesses rather than the jury and that both sources are silent with regard to the reputation of jurors. Contending further that the Founding-Era concern with local juries was based on their familiarity with the community rather than subjection to reputational scrutiny.