In re Boise Cascade Securities Litigation – Case Brief
In re Boise Cascade Securities Litigation, 420 F.Supp. 99 (W.D. Wash. 1976).
Facts: Shareholders of West Tacoma Newsprint sued Boise Cascade Corp. for violations of state and federal securities laws. The litigation became extremely complicated and involved numerous plaintiffs and required the analysis of over $1 billion dollars in transactions over a five year period. An important factual element in the plaintiffs’ claims was the measure of reliance of each party. Boise moved to strike Newsprint’s demand for a jury trial.
Issue: Does the Seventh Amendment guarantee an absolute right to trial by jury without limitation?
Holding and Rule: No. The Seventh Amendment does not guarantee an absolute right to trial by jury without limitation.
An impartial and competent fact finder is central to fairness. At some point the complexity of a case may exceed the ability of a jury to decide the facts in an informed and capable manner. The question is then whether the need for fairness is outweighed by the Seventh Amendment right to trial by jury, even when the jury would not be qualified to determine the facts.
There are three factors which determine the susceptibility of a claim to trial by jury: 1) the premerger custom (i.e. of law and equity) with reference to such questions; 2) the remedy sought; 3) the practical abilities and limitations of juries. The jury that would hear this case over several months of trial would not be a fair cross section of the community. In addition, the court has tools that are unwieldy in the possession of a jury such as the review of daily transcripts, admissions of depositions, review of selected portions of testimony, the ability to study exhibits in depth, and the ability to carry on colloquies with witnesses in an orderly and systematic manner.
Disposition: Boise’s motion to strike Newsprint’s demand for a jury trial granted.