Beacon Theatres, Inc. v. Westover

Brief Fact Summary.

Respondent filed a request with the court to prohibit Petitioner from filing a lawsuit. Petitioner filed a counterclaim and cross-claim, requested a jury trial, and sought damages.

Synopsis of Rule of Law.

A case that involves both legal and equitable claims is entitled to a jury trial when requested by a party.

Facts.

Beacon Theater (Petitioner),a drive-in movie theater, threated to sue Fox West Coast (Respondent), another movie theater, for violating antitrust laws in its movie contracts. Respondent filed a Complaint for Declaratory Relief asking the District Court for a declaratory judgment that its contracts were not antitrust violations and requesting a preliminary injunction to prevent Petitioner from filing a lawsuit. Petitioner filed a counterclaim and cross-claim alleging that Respondent was violating antitrust laws and demanded a jury trial. Petitioner sought damages.

Issue.

Is the Petitioner entitled to a jury trial?

Held.

Yes, the Petitioner is entitled to a jury trial. The decision of the Court of Appeals is reversed.

Dissent.

Justice Stewart

Justice Stewart argued the Court should have denied the writ of mandamus, in deference to the district court judge, because the issues of the case were questions of law.

Discussion.

The Court determined that the writ of mandamus should be granted because the Petitioner was entitled to a jury trial under the Seventh Amendment. The fact that the case involved equitable claims as well as legal claims did not overcome the strong constitutional right to a jury trial. Respondent’s requests for equitable relief in the form of a declaratory judgment and preliminary injunction could be assessed after Petitioner’s legal claim of antitrust violations went to a jury.