Beacon Theatres v. Westover
Encyclopedia
Beacon Theatres v. Westover, 359 U.S. 500 (1959), was a case decided by the Supreme Court of the United States
dealing with jury trial
s in civil matters. The court held that where legal and equitable claims are joined in the same action, the legal claims must be tried by a jury before the equitable claims can be resolved.
The following explanation can be found at the Cornell Law School - Legal Information Institute - United States Constitution site at http://www.law.cornell.edu/anncon/html/amdt7frag3_user.html
Supreme Court of the United States
The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...
dealing with jury trial
Jury trial
A jury trial is a legal proceeding in which a jury either makes a decision or makes findings of fact which are then applied by a judge...
s in civil matters. The court held that where legal and equitable claims are joined in the same action, the legal claims must be tried by a jury before the equitable claims can be resolved.
The following explanation can be found at the Cornell Law School - Legal Information Institute - United States Constitution site at http://www.law.cornell.edu/anncon/html/amdt7frag3_user.html
In Beacon Theatres v. Westover, the Court held that a district court erred in trying all issues itself in an action in which the plaintiff sought a declaratory judgmentDeclaratory judgmentA declaratory judgment is a judgment of a court in a civil case which declares the rights, duties, or obligations of one or more parties in a dispute. A declaratory judgment is legally binding, but it does not order any action by a party. In this way, the declaratory judgment is like an action to...
and an injunction barring the defendant from instituting an antitrustAntitrustThe United States antitrust law is a body of laws that prohibits anti-competitive behavior and unfair business practices. Antitrust laws are intended to encourage competition in the marketplace. These competition laws make illegal certain practices deemed to hurt businesses or consumers or both,...
action against it, and the defendant had filed a counterclaimCounterclaimIn civil procedure, a party's claim is a counterclaim if the defending party has previously made a claim against the claiming party.Examples of counterclaims include:...
alleging violation of the antitrust laws and asking for treble damages. It did not matter, the Court ruled, that the equitable claims had been filed first and the law counterclaims involved allegations common to the equitable claims. Subsequent jury trial of these issues would probably be precluded by collateral estoppelCollateral estoppelCollateral estoppel , known in modern terminology as issue preclusion, is a common law estoppel doctrine that prevents a person from relitigating an issue. One summary is that "once a court has decided an issue of fact or law necessary to its judgment, that decision .....
, hence "only under the most imperative circumstances which in view of the flexible procedures of the Federal Rules we cannot now anticipate, can the right to a jury trial of legal issues be lost through prior determination of equitable claims."