Beacon Theatres, Inc. v. Westover

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Beacon Theatres v. Westover
Seal of the United States Supreme Court
Argued December 10, 1958
Decided May 25, 1959
Full case nameBeacon Theatres, Incorporated v. Westover, United States District Judge, et al.
Citations359 U.S. 500 (more)
79 S. Ct. 948; 3 L. Ed. 2d 988; 1959 U.S. LEXIS 1934; 2 Fed. R. Serv. 2d (Callaghan) 650
Case history
PriorCertiorari to the United States Court of Appeals for the Ninth Circuit, 252 F.2d 864 (9th Cir. 1958)
Holding
Only under the most imperative circumstances can right to jury trial of legal issues be lost through prior determination of equitable claims.
Court membership
Chief Justice
Earl Warren
Associate Justices
Hugo Black · Felix Frankfurter
William O. Douglas · Tom C. Clark
John M. Harlan II · William J. Brennan Jr.
Charles E. Whittaker · Potter Stewart
Case opinions
MajorityBlack, joined by Warren, Douglas, Clark, Brennan
DissentStewart, joined by Harlan, Whittaker
Frankfurter took no part in the consideration or decision of the case.
Laws applied
U.S. Const. amend. VII

Beacon Theatres v. Westover, 359 U.S. 500 (1959), was a case decided by the Supreme Court of the United States dealing with jury trials 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 https://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 judgment and an injunction barring the defendant from instituting an antitrust action against it, and the defendant had filed a counterclaim 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 estoppel, 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."

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