Summary
The Ninth Circuit granted Tsay JBR LLC’s petition for a writ of mandamus and directed the district court to conduct a jury trial on Theresa Brooke’s claim for statutory damages under section 52(a) of California’s Unruh Civil Rights Act. The court held that the claim is legal in nature under the Seventh Amendment because it resembles an eighteenth-century legal action concerning public accommodations and seeks statutory damages serving punitive and deterrent purposes. The court further held that the jury-trial right attaches even though the action also seeks equitable relief under the Americans with Disabilities Act.
Topics
Practice areas
Questions Presented
- Whether a defendant is entitled under the Seventh Amendment to a jury trial on a claim for statutory damages under section 52(a) of the California Unruh Civil Rights Act.
- Whether mandamus is an appropriate remedy for the district court's decision to conduct a bench trial rather than a jury trial on that claim.
Holdings
- The Seventh Amendment entitles parties in federal court to a jury trial on a claim for statutory damages under section 52(a) of the California Unruh Civil Rights Act.
- Mandamus is appropriate to remedy the district court's wrongful denial of a jury trial, and the petition should be granted.
Key quotations
“So long as a case involves a legal claim, the right to a jury trial attaches, even if the case also seeks equitable relief.” (136 F.4th at 1179)
“Because both the historical analog and the nature of the remedy reveal that Brooke’s claim is legal, we hold that the Seventh Amendment entitles parties in federal court to a jury trial on a claim for statutory damages under section 52(a) of the Unruh Act.” (136 F.4th at 1183)
Factual background
Theresa Brooke, a wheelchair user with disabilities, and her husband visited a California hotel while testing compliance with disability-access laws. Brooke alleged that architectural barriers at the hotel deterred her from entering. The district court found that the hotel violated the ADA because its passenger loading zone lacked an access aisle, and that the ADA violation necessarily established an Unruh Act violation. A factual issue remained whether Brooke personally encountered or was deterred by the construction-related violation, affecting her eligibility for statutory damages.
Procedural history
Theresa Brooke sued Tsay JBR LLC under Title III of the Americans with Disabilities Act and the California Unruh Civil Rights Act after alleged architectural barriers deterred her from entering a hotel. The district court granted Brooke partial summary judgment, found an ADA violation and a corresponding Unruh Act violation, and determined that a factual issue remained concerning whether Brooke personally encountered or was deterred by the violation. The district court converted the scheduled jury trial to a bench trial, concluding that the Seventh Amendment jury-trial right did not attach to an Unruh Act statutory-damages claim. Tsay JBR sought mandamus, and the Ninth Circuit granted the petition.
Remand instructions
The district court must set the matter for a jury trial.