In the Tull v. United States case of 1986, the Supreme Court ruled that in civil cases regarding violations of federal statutes where legal and equitable issues are present, a jury trial is required to resolve legal claims while equitable determinations can be made by judges. The case involved James Tull who was accused by the government of violating section 301(a) of the Federal Water Pollution Control Act (FWPCA). He requested a jury trial but was denied on both liability and penalty phases. On appeal, he argued his right to a jury trial under Seventh Amendment had been violated. The Supreme Court agreed with him partially stating that while Mr.Tull did have a right to have his guilt determined by a jury for violation charges under FWPCA which were considered as "legal" issues; however, it disagreed on whether juries should determine penalties or fines which were seen as "equitable" remedies traditionally decided upon by judges.

In the dissenting opinion for Tull v. United States, Justice White argued that the Seventh Amendment did not require a jury trial in civil cases involving statutory penalties. He contended that historically, such cases were tried by judges rather than juries and therefore there was no constitutional right to a jury trial in these circumstances. Furthermore, he believed it would be more practical and efficient for judges to handle these types of complex environmental litigation matters due to their specialized knowledge and expertise. The majority's decision requiring a jury trial could potentially complicate proceedings unnecessarily without providing any additional protection or benefits for defendants.