Chauffeurs, Teamsters and Helpers, Local No. 391 v. Terry, 494 U.S. 558 (1990)
Chauffeurs Local 391 v. Terry is a cornerstone case on the Seventh Amendment right to a jury trial in modern statutory actions.
Does the Seventh Amendment guarantee a right to a jury trial in a duty of fair representation action against a union when the employees seek money damages (including backpay) as a remedy?
The Seventh Amendment preserves the right to a jury trial in suits at common law where legal rights are at stake. To determine whether the right applies in a modern statutory action, courts use a two-step inquiry: (1) compare the statutory action to 18th-century actions brought in the courts of law or equity; and (2) examine the nature of the remedy sought, giving greater weight to the remedy. When plaintiffs seek traditional legal relief—such as compensatory damages—the action is ordinarily triable to a jury. The mere presence of related equitable claims does not eliminate the jury right on legal issues.
Yes. The Seventh Amendment guarantees the employees a right to a jury trial on their duty of fair representation claim against the union because they seek legal relief—money damages for lost wages—rather than equitable restitution.
Terry clarifies that the classification of a remedy as legal or equitable depends on its nature and function in context, not its label. Backpay against a union for breach of the duty of fair representation is legal damages, and the Seventh Amendment attaches. For law students, the case is a prime example of how courts analyze statutory claims under the historical Seventh Amendment framework, and it demonstrates how the remedy typically dominates the analysis. Practically, Terry ensures that unions face jury trials in DFR suits seeking monetary compensation, affecting litigation strategy, settlement leverage, and the framing of claims in labor disputes. It also provides a template for assessing jury-trial rights in other modern statutory contexts.