A proceeding brought by one party against another in a court of law to obtain remedies such as damages.
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Common Examples
6
Inconsistent Special Verdict Prompts New Trial Motion
After a jury trial in federal court, Maya Ortiz and other sales associates obtained a defense verdict from LuxeBay Retailers Inc. on their discrimination claims. The special verdict form nevertheless contained internally inconsistent answers about whether the manager made discriminatory comments. The associates moved for a new trial under Rule 59. The court granted the motion because the inconsistency supplied a traditional ground for relief in a suit at law.
Transient Presence Supports Personal Jurisdiction
Steven Silva was served with process while visiting California on business. The plaintiff sued him in state court for breach of contract seeking damages. Silva moved to dismiss for lack of personal jurisdiction. The court upheld jurisdiction because service on a defendant physically present in the forum has long been recognized as valid in a suit at law.
Burnham v. Superior Court of Cal., County of Marin495 U.S. 604, 618, 110 S.Ct. 2105, 109 L.Ed.2d 631 (1990)
Dennis Burnham married Francie Burnham in 1976 in West Virginia. In 1977 the couple moved to New Jersey, where their two children were born. In July 1987 the Burnhams separated. Mrs. Burnham, who intended to move to California, was visiting her parents in that State when she filed for divorce in New Jersey on grounds of extreme cruelty, seeking spousal and child support, custody of the children, and possession of the family home.
In early August 1987 petitioner visited Mrs. Burnham in California to discuss the children and the separation. He took the children to San Francisco for a few days. Upon returning the children to Mrs. Burnham, petitioner was served with a summons and complaint for divorce filed in California Superior Court that also sought custody of the children. After being served, petitioner returned to New Jersey.
In January 1988 petitioner made a special appearance in the California action and moved to quash service of process on the ground that the court lacked personal jurisdiction over him. The Superior Court denied the motion, and the State Court of Appeal affirmed. The California Supreme Court denied review. The United States Supreme Court granted certiorari to resolve a conflict among the state and federal courts.
Simon Stern filed a federal diversity action seeking damages for breach of contract. The claim would have been timely under federal equitable principles but was barred by the state statute of limitations. The court dismissed the suit because the action at law was governed by state limitations rules.
Guaranty Trust Co. v. York[326 U.S.] at 110
In May 1930 the Van Sweringen Corporation issued $30,000,000 in notes under an indenture naming Guaranty Trust Co. of New York as trustee with power to enforce noteholders' rights. In October 1930 Guaranty and other banks advanced large sums to companies affiliated with the Corporation and controlled by the Van Sweringens. When the Corporation could not meet its obligations, Guaranty participated in an exchange plan under which noteholders could surrender their notes for cash equal to 50 percent of face value plus twenty shares of Van Sweringen stock per $1,000 note; the offer remained open until December 15, 1931.
In 1934 respondent York received $6,000 of the notes as a gift from a donor who had not accepted the exchange offer. In April 1940 three accepting noteholders filed the Hackner suit in federal court charging Guaranty with fraud and misrepresentation in connection with the exchange. York's motion to intervene was denied, and summary judgment for Guaranty was affirmed on appeal.
On January 22, 1942, after her exclusion from the Hackner litigation, York filed the present class action in the United States District Court for the Southern District of New York on behalf of non-accepting noteholders. The complaint, resting exclusively on diversity of citizenship, alleged that Guaranty had breached its trust by failing to protect noteholders' interests when it assented to the exchange offer and by failing to disclose its own self-interest.
The district court granted Guaranty's motion for summary judgment on the authority of the Hackner decision. The Circuit Court of Appeals reversed, holding that a federal court sitting in equity is not required to apply the New York statute of limitations that would govern an identical suit in the New York state courts. The Supreme Court granted certiorari.
Sean Steele sued city police officers in federal court under 42 U.S.C. § 1983 for damages arising from an unlawful search. The defendants argued the claim sounded in equity. The court rejected the argument and allowed the case to proceed as a suit at law for monetary relief.
Monroe v. Pape365 U.S. 167, 174
On October 29, 1958, at approximately 5:45 a.m., thirteen Chicago police officers entered the apartment of James Monroe and his family without a search warrant or arrest warrant. The officers roused the Monroes from bed using flashlights and forced them at gunpoint to stand naked in the living room while ransacking every room, emptying drawers, and ripping mattress covers. Detective Pape struck Mr. Monroe several times with his flashlight and called him "nigger" and "black boy." Other officers hit and kicked several of the children and pushed them to the floor.
Mr. Monroe was then taken to the police station and detained on open charges for ten hours. During this period he was interrogated about a murder, exhibited in lineups, and not permitted to call his family or attorney, although he was not brought before a magistrate despite their availability. He was released without any criminal charges being filed against him.
The complaint alleged that these actions occurred under color of the statutes, ordinances, regulations, customs, and usages of Illinois and Chicago, and that the City had no rules or controls over its police officers, permitting them to act without restraint. The Monroes claimed deprivations of rights under the Fourth and Fourteenth Amendments and sought compensatory and punitive damages from the officers and the City.
The district court dismissed the complaint for failure to state a claim upon which relief could be granted. The Court of Appeals for the Seventh Circuit affirmed the dismissal, and the Supreme Court granted certiorari to review the judgment.
Solomon Silver sued the state of Maine in its own courts for overtime wages under federal law. The state asserted sovereign immunity. The court dismissed the suit at law because Congress had not validly abrogated the state's immunity from private damages actions.
Alden v. Maine527 U.S. 706 (1999)
In 1992, petitioners, a group of probation officers, filed suit against their employer, the State of Maine, in the United States District Court for the District of Maine. The officers alleged the State had violated the overtime provisions of the Fair Labor Standards Act of 1938 and sought compensation and liquidated damages. While the suit was pending, the Supreme Court decided Seminole Tribe of Florida v. Florida in 1996. Upon consideration of that decision, the District Court dismissed petitioners' action, and the Court of Appeals affirmed.
Petitioners then filed the same action in state court. The state trial court dismissed the suit on the basis of sovereign immunity, and the Maine Supreme Judicial Court affirmed in 1998. The Maine Supreme Judicial Court's decision conflicted with the decision of the Supreme Court of Arkansas in Jacoby v. Arkansas Department of Education. In light of the importance of the question presented and the conflict between the courts, the Supreme Court granted certiorari in 1998.
The United States intervened as a petitioner to defend the statute. Petitioners are a group of probation officers who alleged violations of federal overtime requirements by their state employer. The procedural path moved from federal district court through dismissal after Seminole Tribe, to refiling in Maine state court, dismissal there, affirmance by the Maine Supreme Judicial Court, and finally review by the United States Supreme Court.
Offensive Collateral Estoppel Applied in Later Suit
Sofia Stern sued Parklane Hosiery Co. for damages after the SEC had already obtained an injunction against the company in an earlier proceeding. The court permitted the plaintiff to use offensive issue preclusion. The prior equitable judgment supplied findings that bound the defendant in the subsequent suit at law.
Parklane Hosiery Co. v. Shore439 U.S. 322, 334 (1979)
Parklane Hosiery Company, Inc., and eleven of its officers and directors issued a proxy statement in connection with a merger between Parklane and another corporation. Leo Shore, a stockholder of Parklane, filed a class action on behalf of stockholders in the United States District Court for the Eastern District of New York against Parklane and the individual defendants. The complaint alleged that the proxy statement was false and misleading in violation of sections 14(a), 10(b), and 20(a) of the Securities Exchange Act of 1934 and related SEC rules. The complaint sought damages for the class, rescission of the merger, and recovery of costs.
Before Shore’s action came to trial, the Securities and Exchange Commission filed a separate suit against the same defendants in the United States District Court for the Southern District of New York. The SEC complaint alleged that the proxy statement that had been issued by Parklane was materially false and misleading in essentially the same respects as those that had been alleged in the respondent's complaint. After a four-day trial, the District Court found that the proxy statement was materially false and misleading in the respects alleged, and entered a declaratory judgment to that effect. The court permanently enjoined the defendants from further violations of the securities laws and ordered them to offer rescission to shareholders who had tendered shares. The defendants did not appeal this judgment.
Shore then moved for partial summary judgment in the Eastern District of New York action, asserting that the defendants were collaterally estopped from relitigating the issues resolved against them in the SEC action. The District Court denied the motion on the ground that application of collateral estoppel would deny the defendants their Seventh Amendment right to a jury trial. The Court of Appeals for the Second Circuit reversed, holding that a party who has had issues of fact determined against him after a full and fair opportunity to litigate in a nonjury trial is collaterally estopped from obtaining a subsequent jury trial of these same issues of fact. Because of an intercircuit conflict with the Fifth Circuit’s decision in Rachal v. Hill, the Supreme Court granted certiorari.
What distinguishes a suit at law from a suit in equity?
A suit at law seeks remedies such as damages that were historically available in courts of law. A suit in equity seeks remedies such as injunctions or specific performance that were historically available only in courts of equity. Modern procedure has merged the two systems but the distinction still determines whether a jury trial is available and which defenses apply.
Does Rule 59(a)(1)(A) apply only to suits at law?
Yes. Rule 59(a)(1)(A) authorizes a new trial after a jury verdict for any reason that historically supported a new trial in an action at law. Rule 59(a)(1)(B) separately addresses new trials after nonjury trials by reference to rehearings in suits in equity.
Can a party obtain specific performance in a suit at law?
No. Specific performance is an equitable remedy unavailable in a suit at law. A plaintiff seeking specific performance must proceed in equity where the court may refuse relief if the bargain is unconscionable even though damages would be available at law.
How does the distinction between suit at law and suit in equity affect jury trials?
The Seventh Amendment preserves the right to a jury trial in suits at law. Claims that would have been tried to a jury in 1791 receive jury trials today. Equitable claims historically tried to the court alone do not carry a jury right even when joined with legal claims.
5 U.S. (1 Cranch) 137 (1803)
…whenever he receives an injury. It is a general rule that where there is a legal right there is also a legal remedy by suit or action at law. The government of the United States is a government of laws and not of men; it will cease to deserve that appellation if the laws furnish no remedy for the violation of vested legal…