Brief Fact Summary. The Defendants, John and Albert Torcomian (Defendants), operated an Amoco Oil Co. (Plaintiff) franchise, without ever entering into a franchise agreement. The Plaintiff filed suit seeking an injunction, restraining Defendants from continuing to use or occupy the franchise site.
Synopsis of Rule of Law. A defendant is entitled to a jury trial based on a counterclaim, even where the plaintiff’s original claim is one in equity, where the counterclaim is compulsory and contains an element that would give rise to a right to a jury trial.
Issue. Whether the district court erred in refusing to afford Defendants a jury trial.
Held. Yes. The district court’s judgment was vacated and the case remanded. The Court of Appeals for the Third Circuit held that the district court erred in refusing to grant the Defendants a jury trial. Federal law unequivocally holds actions seeking ejectment to be legal, not equitable. An equitable main claim cannot preclude a jury trial on a legal counterclaim, at least when the counterclaim is compulsory. Because the district court could not have properly granted Plaintiff a directed verdict against Defendants, the denial of a jury trial was not harmless error.
But where in a proceeding in equity the plaintiff's title is clear, and all the evidence relating to it is of such a character that a judge, in a trial at law upon the same evidence, would not be at liberty to submit the question of the plaintiff's title to a jury, equity will grant relief, although there has been no adjudication at common law.View Full Point of Law