" Maitland noticed in the mid-thirteenth century the rise of what today is called jury nullification of the law. Juries were reluctant to convict the very young, women, the senile, or first offenders with good reputations. A 1980 study shows a conviction level of indicted people—not much higher than in New York City today—of only 35 percent in about the year 1320. In response, judges did what criminal justice officials in New York do today. They began to resort to plea bargaining. "

― Norman F. Cantor , Inventing the Middle Ages