Dairy Queen, Inc. v. Wood, 369 U.S. 469 (1962)
Dairy Queen, Inc. v.
Whether a plaintiff can avoid the Seventh Amendment right to a jury trial by labeling a claim for money due under a contract as an equitable "accounting," particularly where injunctive relief is also requested; and whether the alleged complexity of accounts justifies denying a jury trial on legal claims.
The Seventh Amendment preserves the right to a jury trial in suits at common law where legal rights are at stake, as measured by the nature of the issues and the remedy sought. A claim seeking a money judgment is legal and triable to a jury, regardless of how it is characterized in the pleadings. When legal and equitable claims are joined, the legal issues must be tried to a jury first (absent the most imperative circumstances), and equitable relief should be shaped consistently with the jury's findings. An equitable accounting is appropriate only where there is an independent basis for equity (such as a fiduciary relationship or truly inextricable and extraordinarily complicated accounts), and even then complexity alone does not supplant the jury; instead, procedural devices (e.g., appointment of a special master) may assist the jury without negating the jury right.
Reversed and remanded. The plaintiffs' demand for an "accounting" was, in substance, a claim for a money judgment—a legal claim triable by a jury. The presence of a request for injunctive relief did not eliminate the jury right on the legal issues. The lower courts erred in striking the jury demand and referring the case to a master in a manner that displaced the jury on legal claims.
Dairy Queen is a foundational Seventh Amendment and Civil Procedure case. It prevents litigants from evading jury trials by strategically styling damages claims as equitable accountings or by appending injunctive requests. The decision operationalizes Beacon Theatres by mandating that courts preserve the jury on legal claims even amid mixed law–equity suits, trying legal issues first where feasible. For law students, the case clarifies the historical law–equity distinction, the substance-over-form approach to remedies, and the proper role of procedural tools (like special masters) to assist rather than replace juries.