Fox owned a movie theatre with exclusive rights to show movies before other movie theatres in the area could show them.
Beacon threatened Fox with an antitrust lawsuit if Fox did not discontinue the practice.
Fox sought a declaration that it was not violating antitrust laws and injunction against Beacon to keep Beacon from filing suit until the declaration was decided.
Beacon filed a counterclaim accusing Fox of antitrust violation. Beacon demanded a jury trial as provided by FRCP 38(b).
The district court viewed the issues raised by Fox to be based in equity and directed that these issues be tried to the court before jury determination of the validity of the antitrust violation. However, one issue that would be answered in equity was whether the two theatres were in competition; this is an element of the antitrust violation that juries typically decide.
Beacon filed a writ of mandamus against the district court judge.
Procedural History:
COA denied Beacon's writ of mandamus.
SCOTUS reversed, granted Beacon's writ of mandamus.
Issues:
How should a court handle a case where legal and equitable issues are intermingled in a single suit?
Holding/Rule:
A court should not deny a party's request for a jury trial unless there are extraordinary circumstances; in cases where both issues must be resolved, legal issues should be decided first by the jury before equitable issues are decided by the judge.
Reasoning:
Under FRCP 1, 2, 18, the same court may try both legal and equitable causes in the same action.
Whatever permanent injunctive relief Fox might be entitled to on the bases of the decision in this case could be given by the court after the jury renders its verdict.
Otherwise, Beacon would compelled to split its antitrust case, trying part to a judge and part to a jury. This would cause the postponement and subordination of Fox's legal claim for declaratory relief.
The right of a trial by jury as declared by the Seventh Amendment or as given by a statute of the United States shall be preserved inviolate.
A trial court should use discretion in cases where having jury trials mingle with issues of equity would cause irreparable harm to a party. The judge could try the equity case first.
Dissent:
None given.
Notes:
If the equitable issues were decided first, then a key element of the legal claim would have been decided by the judge, namely the declaratory judgment requested by Fox about whether the two theatres were in competition.
