Also known as: non-jury trial · nonjury trials · non-jury trials · bench trial
Written by attorneys · grounded in primary & secondary sources — see below
A judicial proceeding in which a judge determines both questions of fact and questions of law without the participation of a jury. The judge alone resolves disputed facts and applies the governing legal standards to reach a final judgment.
Select any source to read its text and confirm it supports the definition.
Naveen Nanda sued Northstar Logistics in federal court for breach of a shipping contract. After a nonjury trial the judge entered judgment for the defendant. Nanda moved under Rule 59 for rehearing on the ground that the judge had overlooked key testimony about delivery delays. The court considered whether the motion satisfied the equitable rehearing standards applicable after a nonjury trial.
Nightingale Healthcare sued Navarro Industries for unpaid invoices after a nonjury trial. The judge entered judgment for the defendant. Nightingale moved to reopen the judgment so the court could take additional testimony on invoice authenticity and amend its findings of fact. The court evaluated whether the new evidence warranted amending the conclusions of law under the post-trial procedures for nonjury cases.
Shareholders sued Parklane Hosiery after the SEC prevailed in a prior nonjury trial on the same disclosure issues. The company argued that the earlier bench-trial findings could not bind it in a later jury action. The court examined whether a full and fair opportunity to litigate in the nonjury proceeding triggered issue preclusion.
Chevron challenged a state rent-control statute in federal court as an unconstitutional taking. The district court conducted a nonjury trial on the economic-impact evidence. After hearing expert testimony on lost profits, the judge made findings on the severity of the burden and entered judgment for the state.
A developer sued a village alleging racial discrimination in the denial of a rezoning petition. The district court held a nonjury trial on the village's intent. The judge evaluated the sequence of events, statements by officials, and statistical patterns before entering findings on discriminatory purpose.
A video producer challenged a federal statute criminalizing certain depictions of animal cruelty. The district court conducted a nonjury trial on the statute's scope and overbreadth. The judge made findings about the categories of speech covered and entered judgment declaring portions of the law unconstitutional.
Rule 52(a) requires the court to find the facts specially and state its conclusions of law separately in any action tried on the facts without a jury. The findings and conclusions may appear on the record after the close of evidence or in an opinion or memorandum of decision. A bare announcement that one party prevailed is insufficient if it fails to distinguish competing evidence or apply the governing legal standard.
Supporting sources
Rule 59(a)(1)(B) permits a new trial or rehearing for any reason that would have supported such relief in equity. Rule 59(a)(2) further authorizes the court to open the judgment, take additional testimony, amend findings of fact and conclusions of law, and direct entry of a new judgment. A motion must be filed no later than 28 days after entry of judgment.
…compensation regardless of whether the legislature had acted in furtherance of legitimate police power objectives. Following a bench trial, the court agreed. Among its factual determinations was the finding that "at the time Lucas purchased the two lots, both were zoned for single-family residential construction and . . .…
…on its face. The District Court entered a preliminary injunction against the enforcement of the regulations, and, after a 3-day
…while he questioned her. Respondent was arrested and charged with domestic battery and with violating his probation. At his bench trial, the trial
…quarreled, and on March 29, 1984, Winans and Carpenter went to the SEC and revealed the entire scheme. This indictment and a bench trial followed. Brant, who had pleaded guilty under a plea agreement, was a witness for the Government. The District Court found, and the Court of Appeals agreed, that Winans had knowingly…
…defendants in this case for the reason that, although they were fully aware of the pendency of the present suit throughout the non-jury trial of the SEC case, they made no effort to protect their right to a jury
Supporting sources
A party that had a full and fair opportunity to litigate factual issues in a nonjury trial may be collaterally estopped from obtaining a subsequent jury trial on those same issues. The Seventh Amendment preserves the jury right only with respect to issues of fact that have not already been fully and fairly adjudicated.
Supporting sources
When no federal statute or rule directly governs, the court weighs the competing state and federal interests. The state's interest in a bench-trial rule tied to housing policy is balanced against the federal system's strong interest in preserving the traditional allocation of functions between judge and jury, especially where the Seventh Amendment is implicated.
Supporting sources