## Facts

- Beacon Theatres, Inc. operated a drive-in theater near San Bernardino, California, and threatened to bring a treble-damages antitrust action challenging Fox West Coast Theatres, Inc.’s “first-run” clearance arrangements.
- Fox, an indoor theater operator, filed a federal action seeking declaratory relief that its clearance contracts were lawful and an injunction restraining Beacon from filing its threatened antitrust damages suit while Fox’s action was pending.
- Beacon answered and asserted a counterclaim (and cross-claim against an intervening exhibitor) alleging a conspiracy to monopolize first-run pictures in violation of the Sherman Act and seeking treble damages under the Clayton Act; Beacon demanded a jury trial.
- The district court, relying on Federal Rules of Civil Procedure 42(b) and 57, ordered that Fox’s declaratory and injunctive claims would be tried first to the court (without a jury), including factual issues overlapping Beacon’s antitrust counterclaim, with Beacon’s damages counterclaim to be tried later.
- Beacon sought mandamus to vacate the sequencing order; the Ninth Circuit denied relief, treating the sequencing decision as within the district court’s discretion.
- The Supreme Court granted review of the mandamus denial.

## Issues

1. Whether a federal district court may try equitable claims first, without a jury, when that trial would determine factual issues common to a party’s legal claims for which the Seventh Amendment guarantees a jury trial.
2. Whether the Declaratory Judgment Act or the Federal Rules permit procedural sequencing that effectively deprives a party of a jury determination on overlapping legal issues.

## Decision

- The Supreme Court reversed the Ninth Circuit and directed relief consistent with preserving Beacon’s jury-trial right.
- The Court held that the district court could not give priority to Fox’s equitable claims in a manner that would preclude a jury trial of common factual issues underlying Beacon’s treble-damages antitrust counterclaim.
- The Court emphasized that only in “the most imperative circumstances” may the right to a jury trial of legal issues be lost through prior determination of equitable claims.
- The Court reasoned that trying the equitable claims first would likely foreclose later jury consideration of the same issues through issue preclusion, making the sequencing order constitutionally improper.
- A dissent would have afforded greater discretion to the district court in managing trial order.

## Legal Principles

- When legal and equitable claims are joined and share common factual issues, the Seventh Amendment requires that the legal issues be tried to a jury first, absent the most imperative circumstances.
- The Declaratory Judgment Act is procedural and preserves jury-trial rights; a party cannot recharacterize essentially legal issues as equitable by seeking declaratory or injunctive relief.
- Treble-damages antitrust claims are legal in nature and carry a constitutional right to jury trial on their factual issues.
- Trial-management tools (including separate trials under Rule 42(b) and declaratory-judgment procedure under Rule 57) may not be used to circumvent the jury right by having a judge determine common facts in equity before the jury.
- Courts must account for the preclusive effect of an initial equitable adjudication; if a nonjury determination would bar subsequent jury resolution of common issues, sequencing must protect the jury’s role.

## Conclusion

The Court held that, in mixed actions presenting overlapping legal and equitable issues, federal courts must preserve the Seventh Amendment by trying the legal issues to a jury before resolving equitable claims, and declaratory-judgment procedure cannot be used to defeat that jury entitlement.


Beacon Theatres, Inc. v. Westover, 359 U.S. 500 (1959)