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Civil Procedure Keyed to Babcock
Beacon Theatres, Inc. v. Westover
Citation:
359 U.S. 500 (1959)Facts
Plaintiff Beacon Theatres built a drive-in movie theatre and notified Fox that its “first run” clearance contracts that gave certain theatres the exclusive rights to show new movies, violated antitrust laws. Before Plaintiff Beacon filed suit Fox filed a Complaint for Declaratory Relief asking the district court for declaratory judgement that Fox’s clearance contracts did not violate antitrust laws and for a preliminary injunction stopping Beacon from filing a lawsuit. Beacon counterclaimed, accusing Fox of violating the Sherman Antitrust Act. Beacon demanded a jury trial. The district judge, Defendant Judge Westover, found that the issues were primarily equitable, and that the issues should be tried before the district judge before proceeding to a jury. Beacon appealed, but the court of appeals upheld the order, finding that Fox’s complaint was partly making a plea for injunctive relief, which is considered an equitable remedy under the authority of a district judge to decide, and that the complaint should be read as a whole.
Beacon appealed further, and the United States Supreme Court granted certiorari.
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