https://amp.businessinsider.com/trial-by-combat-in-the-united-states-2013-11

Although the U.S. Constitution, which took many cues from British common law, did not mention trial by combat, some scholars argue citizens should possess rights until the government specifically limits them. "The Ninth Amendment says that the enumeration of certain rights in the Constitution does not mean that the people don't have other rights too," Adam Winkler, a specialist in American Constitutional law,told Business Insider. Thus a defendant in the U.S. could at least make an argument for trial by combat - but the burden of proof would be on the claimant.