Saturday, December 28, 2013

Tull v. United States case brief

Tull v. United States case brief summary
481 U.S. 412 (1987)

Petitioner, a developer, obtained a writ of certiorari to the United States Court of Appeals for the Fourth Circuit of its decision that he was not entitled to a jury trial on respondent government's civil claims against him under the Clean Water Act, 62 Stat. 1155, 33 U.S.C.S. § 1251, either as to liability, or as the amount of the fine imposed.

Respondent filed an action against petitioner under the Clean Water Act (Act), 62 Stat. 1155, 33 U.S.C.S. § 1251 et seq., seeking fines and injunctive relief, after petitioner dumped fill material into wetlands. The district court denied petitioner's timely request for a jury, found that petitioner had illegally dumped fill into wetlands, assessed fines against him, and granted injunctive relief on land still owned by petitioner. The appellate court affirmed the judgment.


  • On certiorari, the Court held that the Seventh Amendment guaranteed petitioner a right to a jury trial, since the fines imposed by the Act were civil penalties that required a jury trial. 
  • Because respondent's claim for injunctions was joined with its claim for fines, petitioner was entitled to a jury trial on all issues common to both claims. 
  • However, since the Act left the amount of the fines to be decided by the court, and since the amount of the fines was not a fundamental element of a jury trial, petitioner was not entitled to have the jury determine the amount of the fine. 
  • The Court, thus, reversed the judgment of the appellate court and remanded the case.

The Court reversed the judgment of the appellate court and remanded the case because respondent's claim for fines was a legal claim entitling petitioner to a jury trial.

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