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Beacon Theatres, Inc. v. Westover

United States Supreme Court
359 U.S. 500 (1959)


After Beacon Theaters, Inc. (plaintiff) built a drive-in movie theater in California, it notified Fox West Coast Theatres, Inc. (Fox) that it was concerned that Fox’s practice of forming “first run” clearance contracts, i.e., contracts that gave certain theaters in the area exclusive rights to show new movies, was violating antitrust laws. Before Beacon could file suit, Fox filed a Complaint for Declaratory Relief, asking the District Court for a declaratory judgment that Fox’s clearance contracts were not in violation of antitrust laws and requesting a preliminary injunction to prevent Beacon from filing suit. Beacon filed a counterclaim alleging that Fox was violating the Sherman Antitrust Act, and demanded a jury trial. The district court judge, Judge Westover (defendant), found that the issues in the case were basically equitable, and directed that the issues be tried in front of the district court before being submitted to a jury. Beacon appealed, and the court of appeals upheld the order, finding that Fox’s complaint was, in part, making a plea for injunctive relief, which is equitable relief within the purview of the district judge, and the complaint should be read as a whole. Beacon appealed, and the United States Supreme Court granted certiorari.

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