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https://en.wikipedia.org/wiki/Trial_by_combat
So that was before the US became a country.
Wikipedia sadly doesn't mention it, but a few years ago, some Brit decided to challenge what IIRC was a traffic infraction and demand trial by combat. The judge issued a ruling that trial by combat was no longer permissible, so it's officially off the books in the UK under case law.
kagis
Vehicle registration violation.
https://medium.com/lessons-from-history/trial-by-combat-one-mans-attempt-to-beat-a-33-motoring-fine-c7a9c9944d93
However, British courts don't bind the US, not since independence, and last time I looked, it still hadn't been resolved in the US. WP doesn't have any clear case law prohibiting it, though the Brits came close:
Now, IIRC there are some limited forms of dueling -- not to the death, but fights -- that are legally sanctioned in at least one state, IIRC Oregon or Washington state.
goes looking
Washington. And, Texas being Texas, Texas also has a sanctioned form.
https://texascriminaljustice.com/what-is-the-mutual-combat-law-in-texas/
https://worldpopulationreview.com/state-rankings/mutual-combat-states
So I think that either a judge would need to have a different interpretation of the legality of dueling or impact on the right to trial by combat than that Delaware judge -- which might happen -- or the trial by combat would need to occur in Texas and be constrained to not incur serious bodily injury -- like, no killing or maiming -- or be in Washington.
It just so happens that I am in Washington.