Brief Fact Summary. Beacon Theatres, Inc. (Plaintiff) sought by writ of mandamus to review a district court decision to vacate certain orders alleged to deprive it of a jury trial of issues arising out of case brought against it by Fox West Coast Theatres, Inc. (Plaintiff). The United States Court of Appeals for the Ninth Circuit refused the writ, holding that the trial court acted with proper discretion in denying Defendant’s request for a jury trial. The Supreme Court of the United States granted certiorari.
Synopsis of Rule of Law. Only under the most imperative circumstances can the right to a jury trial of legal issues be lost through prior determination of equitable claims.
Issue. Whether a Defendant who seeks both treble damages and equitable relief is entitled to a jury trial?
Held. Yes. Judgment of the United States Court of Appeals for the Ninth Circuit is affirmed. A party who is entitled to injunctive relief may have all issues in their case determined by the judge without a jury regardless of whether legal rights are involved. However, a suit in equity cannot justify denying the Defendant a trial by jury of all the issues in the antitrust controversy. After the jury rendered the verdict, the judge could have granted permanent injunctive relief. The right to a jury trial is a constitutional one and that discretion is very narrowly limited and must be exercised in such a way as to preserve the jury trial. Therefore, the right to a jury trial of legal issues cannot be lost through prior determination of equitable claims.
Dissent. A litigant is entitled to a writ of mandamus to protect a clear constitutional or statutory relief to a jury trial. However, there was no such denial of a right here. When declaratory relief is sought, the right to a jury trial depends upon the basic context in which the issues are presented. The court’s opinion does not hold that a court of equity may not determine legal rights. The Federal Rules of Civil Procedure permit the trial of legal and equitable claims in the same proceeding, but expressly affirm the power of a trial judge to determine the order in which claims shall be heard.
Discussion. The Seventh Amendment of the United States Constitution provides that the right of trial by jury shall be preserved and no fact tried by a jury shall be otherwise re- examined in any court of the United States. There are two parts to the Amendment. The first provides the circumstances under which a litigant has a right to a jury trial and the other indicates what controls the court may impose upon a jury in a case, which the right is guaranteed.