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Civil Procedure Keyed to Field
Beacon Theatres, Inc. v. Westover
Citation:
359 U.S. 500 (1959)Facts
Fox West Coast Theatres operated a movie theatre in San Bernardino, California, exhibiting films under contracts granting exclusive first-run rights with clearance periods preventing other theatres from showing the same films simultaneously. After Beacon Theatres built a drive-in theatre approximately eleven miles from San Bernardino, Beacon notified Fox that contracts barring simultaneous exhibitions violated antitrust laws and threatened treble damage suits. Fox filed a complaint for declaratory relief and injunction, alleging Beacon’s threats constituted duress and coercion causing irreparable harm to Fox’s business relationships and right to negotiate exclusive contracts. Beacon answered and filed a compulsory counterclaim and cross-claim alleging conspiracy between Fox and distributors to monopolize first-run films, requesting three hundred thousand dollars in treble damages and demanding jury trial under Federal Rule 38(b). The district court ordered Fox’s equitable claims tried first to the court, potentially precluding full jury trial through collateral estoppel.
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