Plaintiff sued Defendant for breach of contract. Defendant filed a counterclaim for breach of contract.
There is no entitlement to a jury trial, under the Seventh Amendment, for claims seeking equitable relief.
Marseilles Hydro Power (Plaintiff), a power company, contracted with Marseilles Land and Water Company (Defendant), a canal company, to supply water to the power plant. When the Defendant refused to repair the canal wall, the Plaintiff sued for breach of contract. Plaintiff sought an injunction allowing Plaintiff to repair the canal, a lien on Defendant to enforce payment for repairs, and declaratory judgment for the Plaintiff to no longer pay rent under the contract. Defendant issued a counterclaim for breach of contract, seeking Plaintiff’s unpaid rent under the contract.
Is a party entitled to a jury trial for claims of equitable relief? Did the Defendant timely file a motion for a jury trial under Rule 38(b)?
No, a party is not entitled to a jury trial for claims of equitable relief. Yes, the request for a jury trial was timely and proper for the counterclaim. The decision of the lower court is reversed and remanded.
The Court determined that because the nature of the Plaintiff’s claim was a contract dispute seeking equitable relief and not legal relief, neither party could request a jury trial under that claim. However, the right to a jury trial arose from the Defendant’s counterclaim, which the court considered to be a separate claim involving legal relief. Once the counterclaim issues of rent and which party breached the contract were raised, the parties had ten days under Rule 38(b) to request a jury trial.