Seventh Amendment Civil Trial Rights
By Madison Hess, J.D. | Legally reviewed by Laura Temme, Esq. | Last reviewed August 15, 2024
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The Seventh Amendment to the U.S. Constitution guards the right to a jury trial in certain civil cases and specifies the associated rules and rights under federal law.
Many people associate juries with criminal cases. When they think of a jury, they imagine a judge reading a jury verdict to a criminal defendant. However, the constitutional right to a civil jury trial was recognized with the ratification of the Bill of Rights.
The Text of the Seventh Amendment
The Seventh Amendment of the U.S. Constitution reads:
"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."
Rights Protected by the Seventh Amendment
The legal right to a jury trial exists in cases at common law where the value in controversy exceeds twenty dollars. This amendment not only affirms the role of juries in determining the facts of a case but also protects the finality of their decisions, preventing re-examination by other courts except under common law rules.
The civil trial rights and concepts outlined in the 7th Amendment of the United States Constitution include:
Right to a jury trial: Individuals have the right to a jury trial in civil cases where the value in controversy exceeds twenty dollars.
Common law application: The amendment applies to cases under common law, which is law developed through court decisions and precedents rather than statutes.
The jury's role: The jury is the trier of fact, meaning they are responsible for determining the facts of the case.
Finality of jury decisions: Once a jury has made a decision, it generally cannot be re-examined by another court, except according to the rules of common law.
Protection against government overreach: Ensures that the government cannot arbitrarily deny a person their right to a jury trial in civil cases.
Historical context: Reflects the framers' intent to preserve the right to a jury trial as it was understood at the time of the amendment’s adoption.
Scope and limitations: Although it guarantees a jury trial, the specifics of how this right is applied can vary and are subject to interpretation by the courts.
These points summarize the key aspects of the 7th Amendment regarding civil trial rights.
Key Seventh Amendment Cases
Several key cases have interpreted the 7th Amendment's civil trial rights. Below, we discuss some of the most notable cases:
Parsons v. Bedford
Parsons v. Bedford (1830) is a U.S. Supreme Court case that deals with the right to a jury trial in civil cases. The case arose when Parsons sued Bedford for damages, and the question was whether the Seventh Amendment's guarantee of a jury trial applied to federal courts in Louisiana. The Supreme Court ruled that the Seventh Amendment does apply to federal courts, meaning that people have the right to a jury trial in civil cases in federal courts, including those in Louisiana.
This decision established that federal courts must apply the right to a jury trial in civil cases, even when the case involves state law.
Dimick v. Schiedt
In Dimick v. Schiedt (1935) the U.S. Supreme Court addresses the issue of whether a judge can increase the amount of money awarded by a jury in a civil case. In this case, a car accident injured Schiedt, and the jury awarded him $500. The judge thought this amount was too low and increased it to $1,500. Dimick, the defendant, argued that the judge didn't have the right to change the jury's decision.
The Supreme Court agreed with Dimick, ruling that a judge cannot increase a jury's award of damages without the consent of both parties. This decision emphasized the importance of the jury's role in determining the amount of damages in civil cases.
Beacon Theatres, Inc. v. Westover
Beacon Theatres, Inc. v. Westover (1959) is a U.S. Supreme Court case about the right to a jury trial in civil cases. Beacon Theatres and Fox West Coast Theatres were in a dispute over movie showings. Fox wanted the court to decide the case without a jury, but Beacon argued that they had a right to a jury trial under the Seventh Amendment. The Supreme Court ruled in favor of Beacon Theatres.
This case establishes that when a single case involves both legal and equitable claims, the court must preserve the right to a jury trial for the legal claims, even if a judge tries the equitable claims.
Curtis v. Loether
Curtis v. Loether (1974) addressed whether people have the right to a jury trial in cases involving housing discrimination. The case began when Curtis sued Loether, accusing him of racial discrimination in renting an apartment.
The Supreme Court ruled that under the Civil Rights Act, people do have the right to a jury trial in such cases. This decision was important because it confirmed that individuals facing housing discrimination could seek justice through a jury trial, ensuring that their rights are protected.
Colgrove v. Battin
In Colgrove v. Battin (1973) the U.S. Supreme Court considered the required size of juries in federal civil trials. The issue was whether a six-person jury, instead of the traditional twelve-person jury, was allowed under the Seventh Amendment.
The Supreme Court ruled that a six-person jury is constitutional in federal civil trials. The Court decided that a smaller jury still meets the requirements of the Seventh Amendment and can fairly decide cases. This decision allowed federal courts to use smaller juries in civil cases. It allows courts to accommodate practical considerations in the judicial process.
Teamsters Local No. 391 v. Terry
In Teamsters Local No. 391 v. Terry (1990) the Court decided that the right to a jury trial applies to suits for breach of a union's duty of fair representation, as these suits are akin to legal actions for breach of contract.
These cases highlight various aspects of the 7th Amendment's application and interpretation in the context of civil trials, demonstrating its enduring influence on the American legal system.
The Seventh Amendment creates a right to a jury trial in a state court or federal court in certain cases. It protects a public right in such cases that cannot be taken away by the federal government. It guides Congress when making determinations about laws, and mandates processes for the court system that cannot be disregarded.
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