Also known as:claims at law · action at law · legal claim
Written by attorneys · grounded in primary & secondary sources — see below
A claim for relief historically available in courts of law rather than equity. Such a claim typically seeks money damages and triggers the right to a jury trial under the Seventh Amendment when the amount in controversy exceeds the constitutional threshold.
Sources & Authorities· 4 primary sources
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Cases
Federal Rules
Model Codes
Restatements
How it applies
Common Examples
6
New Trial Motion After Jury Verdict
Cascade Manufacturing sued Crystal Dynamics in federal court for breach of a supply contract and sought only compensatory damages. After a jury returned a verdict for the plaintiff, Crystal Dynamics moved for a new trial under Rule 59. The court evaluated the motion under the standards historically applied to claims at law.
Wrongful Death Claim at Law
Craig Caldwell's estate brought a wrongful death action against a shipping company after a maritime accident. The claim sought damages for the decedent's lost earnings and was filed on the civil docket rather than in admiralty. The court treated the action as a claim at law triable to a jury.
Moragne v. States Marine Lines, Inc.398 U.S. 375, 90 S.Ct. 1772, 26 L.Ed.2d 339
Fraudulent Conveyance Action
Crestview Holdings sued to recover assets allegedly transferred to avoid creditors. The complaint demanded a money judgment and a jury trial. The court classified the action as a claim at law because the relief sought was historically available in courts of law.
Granfinanciera, S.A. v. Nordberg492 U.S. 33, 42 (1989)
Mandamus Petition Treated as Damages Claim
Charlotte Chung petitioned for a writ of mandamus to compel payment of salary allegedly owed by a federal officer. The court evaluated whether the underlying request for relief aligned with historic practice for claims at law seeking money damages.
Marbury v. Madison5 U.S. (1 Cranch) 137 (1803)
Accounting Claim Recharacterized
Citadel Security demanded an accounting of profits from a former partner. Because the underlying remedy was a money judgment rather than coercive equitable relief, the court held that the claim remained one at law and preserved the jury right.
Dairy Queen, Inc. v. Wood369 U.S., at 479 n.20
Declaratory Judgment Converted to Damages
Colin Chambers sought a declaratory judgment that a contract entitled him to royalties. The court determined that the declaration would function as a claim at law for money and therefore required a jury trial on the underlying factual disputes.
Beacon Theatres, Inc. v. Westover359 U.S. 500 (1959)
Common questions
Frequently Asked
2
When does a claim qualify as one at law for Seventh Amendment purposes?+
A claim qualifies as one at law when it seeks relief historically available in courts of law, such as money damages, rather than equitable remedies like injunctions or specific performance. The nature of the remedy requested determines the classification even if the underlying facts involve maritime or other specialized subject matter.
Supporting sources
How does Rule 59 treat motions for new trial in actions involving claims at law?+
Rule 59(a)(1)(A) authorizes a new trial after a jury verdict for any reason a new trial would have been granted in an action at law under historic practice. This standard incorporates common-law grounds such as verdicts against the weight of the evidence or prejudicial legal error.
Supporting sources
5 U.S. (1 Cranch) 137 (1803)Property
…whenever he receives an injury. It is a general rule that where there is a legal right there is also a legal remedy by suit or action at law. The government of the United States is a government of laws and not of men; it will cease to deserve that appellation if the laws furnish no remedy for the violation of vested legal…