Tull v. United States – Case Brief
Tull v. United States, 481 U.S. 412, 107 S.Ct. 1831, 95 L. Ed. 2d 365 (1987).
Facts: The United States (P) filed a civil suit against Tull (D) for discharging fill material into wetlands in violation of the Clean Water Act. P sought over $22 million and injunctive relief. The district court denied Tull’s motion for a jury trial and entered judgment for P for $325,000. The court of appeals affirmed the denial of a jury trial and the Supreme Court granted cert.
Issue: 1) What is the test for determining whether the Seventh Amendment preserves the right to a jury trial on the merits? 2) For cases in which the Seventh Amendment preserves the right to a trial by jury, does the Seventh Amendment also mandate the right to a jury trial for the determination of civil penalties?
Holding and Rule (Brennan): The Seventh Amendment preserves the right to a jury trial on the merits in actions that are analogous to suits at common law. 2) No. For cases in which the Seventh Amendment mandates the right to a trial by jury, the Seventh Amendment does not mandate the right to a jury trial for the determination of civil penalties.
Under the common law, civil penalties could only be enforced in courts of law and the party therefore had the right to a trial by jury. The Clear Water Act authorizes financial penalties for violations and therefore does not merely provide equitable relief via injunction. P’s claims are analogous to common law actions for public nuisance and actions in debt and are therefore entitled to trial by jury. If an equitable claim is joined with a legal claim, the right to a jury trial remains. The right to jury trial was improperly denied.
The Seventh Amendment is silent on the issue of whether a jury must determine both the liability and the amount of the remedy. The jury’s role in the assessment of a remedy is not necessary to preserve the common law right of a trial by jury as the assessment of the civil penalty is not a fundamental part of a trial by jury. The jury must determine liability and the trial judge may determine the amount of the penalty.
Disposition: Reversed and remanded.
Concurring and Dissenting (Scalia): The amount of penalty is subject to jury determination. There is no precedent in a civil court for the finding of liability by a jury and the amount of the remedy by a judge.