Chauffeurs, Teamsters & Helpers, Local No. 391 v. Terry

Brief Fact Summary.

Respondents sued Petitioner for firing them and Petitioners for not fairly representing them after they were fired. Respondent requested money damages and a jury trial and Petitioners argued that there was no right to a jury trial in this type of case.

Synopsis of Rule of Law.

Under the Seventh Amendment, parties presenting issues of legal rights and requesting legal relief have a right to a jury trial.

Facts.

Twenty-seven unionized truck drivers (Respondents) sued McLean Trucking Co. (Petitioner) for firing the drivers in breach of their collective-bargaining agreement and their unions, Chauffeurs, Teamsters, and Helpers Local Union No. 391 (Petitioners), for violating their duty of fair representation. Respondents requested monetary damages in the form of lost wages and health benefits and requested a jury trial. Petitioners moved to strike the request arguing that there was no right to a jury trial in a case about duties of fair representation because the claim was equitable and not legal.

Issue.

Do the Respondents, seeking money damages from Petitioners for a breach of the duty of fair representation, have a right to a jury trial?

Held.

Yes, Respondents have a right to a jury trial. The lower court’s decision is affirmed.

Dissent.

Justice Kennedy

Justice Kennedy argued that the Court did not conduct a proper analysis of English history when it rejected the parties analogies and instead conducted its own consideration of the nature of the issues in this case.

Concurrence.

Justice Brennan

Justice Brennan agreed with the Court’s decision, but believed that the test should be simplified to only examine the type of relief the party requested.

Justice Stevens

Justice Stevens argues that, while common-law analogue is helpful for these cases, the Court put too much emphasis on finding one, making the lawsuit and the law more complex than necessary.

Discussion.

The Court first determined that the Respondents’ claim involved both legal and equitable issues because issue of the breach of the collective-bargaining agreement must be determined alongside the issue of the breach of duty of fair representation. The Court next determined that the relief sought in the form of lost wages and health benefits should be considered legal because this relief was not restitutionary and the Respondent only sought monetary damages. Taken together, the Respondents were entitled to a jury trial under the Seventh Amendment.