n6 The rents issue has plagued the courts for the last century. In determining rights rooted in the common law, it is relevant for a court to review the underlying principles established in historical case law addressing the same issue. The United States Supreme Court has exhaustively reviewed the historical bases for well-established rights, such as the right to jury trial, the doctrine of sovereign immunity, and the guarantee against double jeopardy, in interpreting the contemporary analogue of common law rights. See Granfinanciera, S.A. v Nordberg, 492 U.S. 33; 109 S. Ct. 2782; 106 L. Ed. 2d 26 (1989); Will v. Michigan Dept. of State Police, 491 U.S. 58; 109 S. Ct. 2304; 105 L. Ed. 2d 45 (1989); United States v. Wilson, 420 U.S. 332; 95 S. Ct. 1013; 43 L. Ed. 2d 232 (1975). For this reason, the court looks to the principles of rights to rents as established in California common law in order to interpret Cal. Civ. Code @ 2938. However, the court notes that the terminology used in historical cases has evolved over time.