Seventh Amendment to the United States Constitution
Amendment VII (the Seventh Amendment) of the United States Constitution, which is part of the Bill of Rights, states:In Suits at common law, where the value in controversy shall exceed twenty dollars, the right of trial by jury shall be preserved, and no fact tried by a jury, shall be otherwise re-examined in any Court of the United States, than according to the rules of the common law.
The right to a jury trial in civil suits, though a simple right to determine in the majority of cases, can in certain circumstances become complicated due to the distinction between suits "at common law" and suits at equity. Historically in English courts, equity was contrasted with law as a means by which judges could make decisions based on principles of fairness addressed to the parties at hand, in courts of chancery rather than legal principles in courts of law. Because equity required a careful balancing of moral considerations by judges, there was no right to a jury in cases involving equitable relief, and the Seventh Amendment did not alter this tradition.
Though at one time this was an easier distinction to make, the line was seriously blurred after the 1938 adoption of the Federal Rules of Civil Procedure (FRCP), which merged cases at law and at equity under one system in federal courts. Legal relief (usually in the form of a monetary judgment) and equitable relief (such as an injunction) may now be requested in the same case. Additionally, some claims are viewed as historically legal and some equitable, and under the FRCP, multiple claims may be brought in the same suit.
One way for courts to deal with this morass is to bifurcate trials—to separate the legal and equitable claims and issues into separate proceedings, with the jury deciding the former and the judge the latter. Whether handled in separate trials or in one, the factual issues in common must be tried by the jury first, with the judge's equitable rulings conforming afterwards. Otherwise, the judge's ruling on the equitable issues would have the effect of collateral estoppel—predetermining the jury's handling of the facts and thus limiting the right to a jury trial on the legal issues.
Under the FRCP, the right to a jury trial is considered waived if no party requests it in a timely motion.
The Supreme Court of the United States has held that the Seventh Amendment has not been "incorporated" by the Fourteenth Amendment to apply to the States, and so applies only in federal courts (see Incorporation under due process). Each State is therefore free to decide in its own laws and constitution whether to grant the right of jury trial in civil suits.
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