There are two types of claims that can be made in a civil
lawsuit, legal claims and equitable claims. There are different rules for how
each claim is adjudicated. Sometimes, a plaintiff might have a case involving
both claims. If so, which claim should be adjudicated first? In the case of Beacon
Theatres v. Westover (359 U.S. 500
(1958)), the US Supreme Court found that since there is a right to a jury on a
legal claim, when a case has both equitable claims and legal claims, the legal
claim must be tried first.
Under the preclusion
doctrine, once a claim has been
determined that decision will be generally binding on future
adjudications.
Therefore, if the equitable
claim were to be tried first, the facts decided in connection with that
claim would then be treated as having been established for the purposes of
the legal claim. This would mean that the issues of fact which the jury
would decide for the legal claim would already have been decided by the
judge as part of the equitable claim.
In this case, the initial suit
was brought for an injunction,
which is an equity court claim. But the countersuit was for money damages,
which is law court claim. In theory, you'd try the original suit before
the countersuit, but in this case, the countersuit needed to be tried
first so a jury could decide the facts.
