Coast Village, Inc. v. Equilon Enterprises, LLC

MEMORANDUM *

This action arises under the Petroleum Marketing Practices Act (“PMPA”), 15 U.S.C. §§ 2801-2841 , as well as several California statutes.

1. Plaintiffs argue that they were entitled to a jury trial on their PMPA claim. On de novo review, Del Monte Dunes at Monterey, Ltd. v. City of Monterey, 95 F.3d 1422, 1426 (9th Cir.1996), aff'd, 526 U.S. 687 , 119 S.Ct. 1624 , 143 L.Ed.2d 882 (1999), we disagree.

Plaintiffs reason that, because the issues contained both factual and legal components, a jury was required to decide the factual elements. This argument is unavailing; district courts ably resolve factual issues every day. See Walters v. Reno, 145 F.3d 1032, 1047 (9th Cir.1998) (noting that a district court’s decision to grant a permanent injunction involves “factual, legal, and discretionary components”).

Rather, the character of the relief sought is the most important factor in determining whether rights created by a federal statute are analogous to suits at common law and, thus, give rise to the right to a jury trial. Spinelli v. Gaughan, 12 F.3d 853, 855-56 (9th Cir.1993). Generally, parties seeking purely equitable relief do not have a right to a jury trial.…