798 F.3d 26
1st Cir.2015Background
- Plaintiff Faustino González-Oyarzun sued his employers in federal court under the ADEA and Puerto Rico law; defendants moved to dismiss based on a separation agreement forum-selection clause requiring litigation in Puerto Rico state court.
- González-Oyarzun argued the forum-selection clause was invalid because Puerto Rico does not provide civil jury trials and he had not waived his Seventh Amendment right.
- The district court ordered supplemental briefing on whether the Seventh Amendment applies to Puerto Rico, and notified the Commonwealth and its Office of Courts Administration.
- The district court held the forum-selection clause valid and dismissed the case, but also entered a declaratory judgment that Puerto Rico must afford civil litigants the Seventh Amendment jury right (incorporation via Fourteenth Amendment).
- The Commonwealth and the Office of Courts Administration appealed only the declaratory-judgment portion; González-Oyarzun did not appeal the dismissal or forum-selection ruling.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Puerto Rico must provide Seventh Amendment civil jury trials (i.e., is the Seventh Amendment incorporated against the states/Commonwealth) | González-Oyarzun: The Seventh Amendment right applies and was not waived; thus forum-selection clause that funnels him to a non-jury forum is invalid | Commonwealth/OCA: Existing Supreme Court precedent holds states need not provide Seventh Amendment civil jury trials; district court lacked basis to declare otherwise | The court vacated the district court's declaratory judgment because it conflicted with controlling Supreme Court precedent that states are not constitutionally required to provide civil jury trials; remanded for amended judgment |
| Whether the district court properly issued a declaratory judgment sua sponte on this constitutional question | González-Oyarzun: Implicitly supported exploring Seventh Amendment issue to resolve forum clause dispute | Commonwealth/OCA: District court should not have decided a constitutional issue neither party requested and may have lacked jurisdictional basis to involve them | The panel noted discretion concerns and that issuing such declaratory relief was at least questionable, but the judgment was vacated on precedent grounds rather than solely on discretionary error |
| Whether McDonald v. City of Chicago overruled prior Seventh Amendment incorporation cases | González-Oyarzun: Argued implication that McDonald supports incorporation | Commonwealth/OCA: McDonald did not overrule prior Seventh Amendment precedent | Held: McDonald did not overrule prior cases; stare decisis and prior Supreme Court decisions remain controlling |
| Whether Eleventh or other sovereign-immunity issues barred the declaratory judgment | Commonwealth/OCA: Raised Eleventh Amendment and related jurisdictional defenses | Gonzalez: Did not press an appeal on dismissal; district court had added Commonwealth entities and appellants delayed arguing service defects | The panel avoided resolving Eleventh Amendment questions because the merits issue (conflict with Supreme Court precedent) was dispositive |
Key Cases Cited
- City of Monterey v. Del Monte Dunes at Monterey, Ltd., 526 U.S. 687 (states not required to provide civil jury trials)
- Gasperini v. Ctr. for Humanities, Inc., 518 U.S. 415 (limits on applying federal standards to state-law damages; discusses jury-trial issues)
- Wagner Elec. Mfg. Co. v. Lyndon, 262 U.S. 226 (early precedent on non-incorporation of Seventh Amendment)
- Minneapolis & St. Louis R.R. Co. v. Bombolis, 241 U.S. 211 (Seventh Amendment not binding on states)
- McDonald v. City of Chicago, 561 U.S. 742 (incorporation doctrine; did not overrule prior Seventh Amendment decisions)
- Duncan v. Louisiana, 391 U.S. 145 (example of incorporation of other constitutional rights against states)
- Rodriguez de Quijas v. Shearson/Am. Express, Inc., 490 U.S. 477 (lower courts must follow directly controlling Supreme Court precedent)