Tull v. United States - 481 U.S. 412, 107 S. Ct. 1831 (1987)

Rule:

The Seventh Amendment provides that, in suits at common law, where the value in controversy shall exceed $ 20, the right of trial by jury shall be preserved. Courts construe this language to require a jury trial on the merits in those actions that are analogous to suits at common law. Prior to the Seventh Amendment's adoption, a jury trial was customary in suits brought in the English law courts. In contrast, those actions that are analogous to 18th-century cases tried in courts of equity or admiralty do not require a jury trial. This analysis applies not only to common-law forms of action, but also to causes of action created by congressional enactment.

Facts:

The Federal Government filed an action against petitioner under the Clean Water Act (Act), 62 Stat. 1155, 33 U.S.C.S. § 1251 et seq., seeking fines and injunctive relief, after petitioner dumped fill material into wetlands. The district court denied petitioner's timely request for a jury, found that petitioner had illegally dumped fill into wetlands, assessed fines against him, and granted injunctive relief on land still owned by petitioner. The appellate court affirmed, rejecting the petitioner’s argument that, under the Seventh Amendment to the Federal Constitution, he was entitled to a jury trial. A writ of certiorari was granted. 

Issue:

Under the Seventh Amendment to the Federal Constitution, was the petitioner entitled to a jury trial? 

Answer:

Yes.

Conclusion:

On certiorari, the Court held that the Seventh Amendment guaranteed petitioner a right to a jury trial, since the fines imposed by the Act were civil penalties that required a jury trial. Because the Federal Government’s claim for injunctions was joined with its claim for fines, petitioner was entitled to a jury trial on all issues common to both claims. However, since the Act left the amount of the fines to be decided by the court, and since the amount of the fines was not a fundamental element of a jury trial, petitioner was not entitled to have the jury determine the amount of the fine. The Court, thus, reversed the judgment of the appellate court and remanded the case.