## Facts

- Radiant Research, Inc. contracted with pharmaceutical companies to oversee human clinical drug trials.
- Dr. Craig L. Leonardi entered consulting agreements with Radiant to conduct trials; the agreements included restrictive covenants barring him for one year from working directly with certain pharmaceutical companies unless Radiant acted as intermediary.
- Leonardi terminated the relationship in November 2001 after giving about two weeks’ notice and continued conducting trials outside Radiant’s involvement.
- Radiant sued Leonardi for injunctive relief and damages, alleging claims including breach of contract, anticipatory repudiation, tortious interference, and civil conspiracy, and sought to enforce the restrictive covenants by injunction.
- Leonardi asserted affirmative defenses (including laches, estoppel, and unclean hands) and filed counterclaims for breach of contract, breach of the implied covenant of good faith and fair dealing, and declaratory relief; he sought damages.
- After an evidentiary hearing, the circuit court denied Radiant’s request for a preliminary injunction, citing limited practical effect and concerns including patient impact, regulatory status, and the public interest in continuing medical research.
- With claims and counterclaims still pending, the circuit court stated it would try the equitable matters to the court and, invoking the equitable cleanup doctrine, denied Leonardi a jury trial on his legal damages counterclaim.
- Leonardi sought a writ of prohibition to prevent the circuit court from trying his legal counterclaim without a jury.

## Issues

1. Whether the equitable cleanup doctrine permitted the circuit court to retain equity jurisdiction and adjudicate Leonardi’s legal damages counterclaim without a jury based solely on Radiant’s pleaded equitable claims.
2. Whether denying a jury trial on Leonardi’s legal damages counterclaim violated the Missouri constitutional right to jury trial when equitable relief was no longer sufficiently necessary to sustain equity jurisdiction.
3. Whether prohibition was an appropriate remedy to prevent the trial court from proceeding without a jury on a claim triable as of right.

## Decision

- The Supreme Court of Missouri made the preliminary writ of prohibition absolute as modified.
- The Court held the equitable cleanup doctrine could not be used to deny Leonardi a jury trial on his legal counterclaim for damages when the equitable basis for continued equity jurisdiction was insufficient.
- The circuit court was prohibited from proceeding to adjudicate Leonardi’s legal damages counterclaim without a jury.

## Legal Principles

- Equity jurisdiction is exceptional and depends on the inadequacy of a remedy at law; if equitable relief fails or becomes insubstantial, equity does not retain jurisdiction to decide remaining legal claims merely to dispose of the entire controversy.
- The equitable cleanup doctrine allows a court of equity to decide related legal matters only when proper equitable jurisdiction exists; it does not independently create or preserve equity jurisdiction.
- The Missouri constitutional right to a jury trial applies to legal claims; that right cannot be defeated by a plaintiff’s inclusion of equitable claims when equitable grounds no longer justify trying the matter in equity.
- Prohibition is available to prevent a trial court from acting in excess of its equitable authority by proceeding without a jury on legal claims that must be tried to a jury upon timely demand.

## Conclusion

The court restricted use of the equitable cleanup doctrine and required that a defendant’s legal damages counterclaim be tried to a jury when equitable jurisdiction was no longer adequately supported, enforcing Missouri’s constitutional guarantee of jury trial for legal causes of action.


State ex rel. Leonardi v. Sherry, 137 S.W.3d 462 (Mo. 2004) (en banc)