Arrow Communication Laboratories, Inc. v. Pico Products, Inc.
Docket: Appeal No. 1
Court: Appellate Division of the Supreme Court of the State of New York; September 29, 1995; New York; State Appellate Court
Order unanimously affirmed with costs. The Supreme Court correctly denied the defendant's motion to strike the plaintiff’s jury demand. The plaintiff's first cause of action seeks a declaratory judgment regarding the License Agreement, which includes determining the rights of the parties, fixing amounts due, and awarding a money judgment for alleged overpayments. The second cause of action involves funds the plaintiff paid into an escrow account following a temporary restraining order. The right to a jury trial is strongly protected and only yields under compelling circumstances. The determination of whether a declaratory judgment action permits a jury trial is based on whether the underlying claims are legal or equitable. If monetary relief is adequate for the plaintiff's claims, a jury trial is warranted. The first cause of action not only seeks declaratory relief but also a monetary judgment for overpayments, thus entitling the plaintiff to a jury trial. Both causes of action hinge on the interpretation of the ambiguous License Agreement, which necessitates extrinsic evidence, making it a factual question for a jury. The defendant's argument that the plaintiff forfeited its right to a jury trial due to potential equitable requests in the complaint is unfounded; requests for monetary damages maintain the legal nature of the claim. Additionally, the request for an accounting does not alter the primary demand for monetary damages, thus the action is legal and not equitable. The defendant's assertion that the equitable nature of its counterclaims prevents a jury trial for the plaintiff's claims is also rejected. The counterclaims, which seek monetary judgments under the License Agreement, are legal in nature. Even if the counterclaims were equitable, they cannot obstruct the plaintiff's right to a jury trial for its legal claims.