JAMES H. MARSHALL, JR., PETITIONER,
v.
HAROLD H. SPRECHER, RESPONDENT
AI-generated. These summaries, headnotes, and key points are machine-generated and may contain errors or omissions. Always verify against the full opinion text below. Not legal advice.
A defendant sought a jury trial in a breach of covenant not to compete action where the plaintiff also sought equitable relief (injunction) and damages. The court held that because the factual issue of breach would be determined in the equitable proceeding and would collaterally estop the jury trial on damages, denying a jury trial on all issues violated the defendant's right to trial by jury.
The trial court departed from the essential requirements of law by denying the defendant a jury trial on all issues. When the threshold factual determination in the equitable aspect (whether the covenant was breached) would collaterally estop the jury's consideration of that same issue in the damages claim, the defendant is entitled to a jury trial on all issues.
[1] A party is entitled to a jury trial on all issues triable by a jury, even when the case also involves equitable claims.
[2] A trial court errs by denying a jury trial on damages when the resolution of the equitable claim by the court would bind the jury through collateral estoppel.
Previewing 2 of 4 headnotes on this case. FLexlaw’s editorially structured points of law — every proposition, pinpointed — are reserved for members.
Join FLexlaw to unlock all legal intelligence“A threshold factual determination by the trial court in the equitable aspect of this matter, i.e. that the covenant was or was not breached, would bind a subsequent jury through collateral estoppel and thus deny the defendant a trial by jury in the resolution of the claim for damages.”
Establishes the core legal principle that collateral estoppel from equitable proceedings can violate jury trial rights when identical issues are at stake in law claims.
Previewing 1 of 3 key quotes on this case — the court’s exact language, pinpointed for members.
Join FLexlaw to unlock all legal intelligenceThe plaintiff filed a single-count complaint alleging breach of a covenant not to compete and sought temporary and permanent injunctive relief as well…
The full statement of facts, procedural history, and disposition for this case are member content.
Join FLexlaw to unlock all legal intelligence© FLexlaw, Inc. — AI-generated enrichments are proprietary. All rights reserved.
Explore caselaw by topic → Browse Breach Of Covenant Not To Compete cases and more on FLexlaw
FRANK, Acting Chief Judge.
The petition for writ of certiorari before us arises from a single count complaint alleging the breach of a covenant not to compete. The plaintiff was granted temporary injunctive relief and now seeks a permanent injunction and damages. Two orders entered by the trial court, one setting the plaintiffs application for an injunction for a nonjury trial and the other denying the defendant’s request for jury trial, are challenged. We have jurisdiction. Valiante v. Allstate Insurance Co., 462 So. 2d 590 (Fla. 2d DCA 1985); Spring v. Ronel Refining, Inc., 421 So. 2d 46 (Fla. 3d DCA 1982).
The defendant filed a demand, for jury trial on all issues triable by a jury. The plaintiff filed a motion to set his entitlement to an injunction for nonjury trial and the defendant filed an objection. The trial court entered an order setting the injunctive claim for nonjury trial. The defendant filed a motion to vacate that order and a motion to set the case for jury trial. The trial court denied the motions and the defendant filed the present petition.
The central issue in the damage claim, entitling the defendant to a jury trial, is indistinguishable from the pivotal issue associated with the request for in-junctive relief, an equitable proceeding not entitling the defendant to a jury trial. We have determined that the trial court departed from the essential requirements of law in denying a jury trial of all issues. A threshold factual determination by the trial court in the equitable aspect of this matter, i.e. that the covenant was or was not breached, would bind a subsequent jury through collateral estoppel and thus deny the defendant a trial by jury in the resolution of the claim for damages. See Chenery v. Crans, 497 So. 2d 267 (Fla. 2d DCA 1986); Magram v. Raffel, 443 So. 2d 396 (Fla. 3d DCA 1984). Cf. Sarasota-Manatee Airport Authority v. Alderman, 238 So. 2d 678 (Fla. 2d DCA 1970) (trial court did not err in ordering that the threshold issue of whether there had been a taking, an equitable issue, would be determined by the court and questions of compensation would be submitted then to a jury where there was no possibility of collateral estoppel through the judge’s determination of facts triable to a jury).
Accordingly, the petition for writ of certiorari is granted, the trial court’s orders are quashed, and the matter remanded to the trial court for further proceedings not inconsistent with this opinion.
PARKER and ALTENBERND, JJ., concur.
Cases With Similar Vibessemantic neighbors from the corpus
Citator
Cited By
-
Billian v. Mobil Corp., 710 So. 2d 984 (Fla. 4th DCA 1998)…ry in an action at law are sufficiently similar to the fact issues on a related equitable claim, the trial court is bound by the jury’s findings of fact in making its ruling on the equitable claim. See Adams, 248 So. 2d at 684; Marshall v. Sprecher, 559 So. 2d 1280, 1281 (Fla. 2d DCA 1990); Chenery v. Crans, 497 So. 2d 267, 269 (Fla. 2d DCA 1986). Legal and equitable issues are “sufficiently similar” or “intertwined” if a jury, in order to return a verdict in an action at law, would necessarily have to decide…
-
Dimitrios Georgos Kavouras v. Mario City Rest. Corp., 88 So. 3d 213 (Fla. 3d DCA 2011)…ve a jury decide the case so as to preserve the parties’ right to a jury trial. See, e.g., Yer Girl Tera Mia v. Wimberly, 962 So. 2d 993, 996 (Fla. 5th DCA 2007); Billian v. Mobil Corp., 710 So. 2d 984, 992 (Fla. 4th DCA 1998); Marshall v. Sprecher, 559 So. 2d 1280, 1281 (Fla. 2d DCA 1990); Vine v. Scarborough, 517 So. 2d 726, 728 (Fla. 3d DCA 1987). Appellees contend that in this case there is no irreparable injury because there is no risk of inconsistent verdicts. This argument, however, ignores the reality…
-
Marlette v. Carullo (Fla. 2d DCA 2022)…en the issues of fact decided by a jury in an action at law are inextricably woven with the issues of fact in an equitable claim, the trial court is bound to the findings of fact by the jury. Billian, 710 So. 2d at 992; cf. Marshall v. Sprecher, 559 So. 2d 1280, 1281 (Fla. 2d DCA 1990) ("A threshold factual determination by the trial court in the equitable aspect of this matter, i.e. that the covenant was or was not breached, would bind a subsequent jury through collateral estoppel and thus deny the de…
Previewing 3 of 4 citing cases — full citator treatment, depth of discussion, and citing context are member features.
Join FLexlaw to unlock all legal intelligenceAuthorities Cited
- Spring v. Ronel Ref., Inc., 421 So. 2d 46 (Fla. 3d DCA 1982)
- Sarasota-Manatee Airport Auth. v. Alderman, 238 So. 2d 678 (Fla. 2d DCA 1970)
- Valiante v. Allstate Ins. Co., 462 So. 2d 590 (Fla. 2d DCA 1985)
- Garcia v. State, 443 So. 2d 396 (Fla. 3d DCA 1984)
- Isadore H. Magram and Magram Motor Cars v. Blair A. Raffel and Allan R. Knight, 443 So. 2d 396 (Fla. 3d DCA 1984)
- Augustine J. Chenery v. Crans, 497 So. 2d 267 (Fla. 2d DCA 1986)