In Beacon Theatres, Inc. v. Westover, the U.S. Supreme Court ruled that when a lawsuit involves both legal and equitable claims, the right to a jury trial cannot be denied for the legal claims just because they are connected with or incidental to equitable issues. In this case, Fox West Coast Theatre Corporation filed an antitrust suit against Beacon Theatres seeking an injunction (an equitable remedy) and damages (a legal claim). However, the district court decided to try all issues without a jury due to their interconnectedness which was appealed by Beacon Theatres arguing its constitutional right for a jury trial on its counterclaim for damages under Seventh Amendment of Constitution was violated. The Supreme Court agreed with Beacon stating that if there is any doubt as to whether or not an issue should be tried by a jury then it must go before one.

In the dissenting opinion for Beacon Theatres, Inc. v. Westover, Justice Frankfurter argued that the majority's decision undermined the traditional role of equity jurisdiction in American law. He contended that historically, courts of equity had discretion to withhold relief when a legal remedy was adequate and suggested this principle should have been applied in this case. Furthermore, he disagreed with the majority's interpretation of Seventh Amendment rights to jury trials as absolute and unqualified; instead arguing they were subject to historical practice which allowed equitable claims to be decided by judges rather than juries. In his view, allowing Beacon Theatres' counterclaim for an injunction against antitrust violations (an equitable claim) to proceed before Fox West Coast Theatre’s claim for damages (a legal claim), did not violate any constitutional right but simply followed established principles governing relations between concurrent jurisdictions at law and in equity.