Beacon Theatres, Inc. v. Westover
United States Supreme Court
359 U.S. 500 (1959)
After Beacon Theatres (plaintiff) built a drive-in movie theater in California, it warned Fox West Coast Theatres that Fox's exclusive-rights "first run" clearance contracts with other theaters might violate antitrust law. Before Beacon could sue, Fox filed for declaratory relief asking the district court to declare its contracts lawful, plus a preliminary injunction blocking Beacon from suing. Beacon counterclaimed under the Sherman Antitrust Act and demanded a jury trial. The district judge (Judge Westover, defendant) decided the case was essentially equitable and ordered the equitable issues tried first, before a judge, ahead of any jury trial. The court of appeals affirmed. Beacon appealed to the Supreme Court.
Whether, when legal and equitable issues exist in the same case, the legal issues must be tried by a jury before the equitable issues are resolved by a judge.