Employee was wrongfully denied jury trial on wrongful termination claim
Jeffrey Benjamin appealed after the trial judge in Iosco County ruled that he was not entitled to a jury trial of his wrongful discharge claim. Benjamin's original complaint sought civil damages and also asked for "equitable" relief--the latter is a distinction retained from the English common law under which the Queen's Courts could grant injunctions or other non-monetary relief, but without relying upon a jury.
Jury determinations were utilized in the King's Courts where money relief was the only option available for legal relief. When American jursidictions acted to preserve the "right to jury trial" as it existed in the [English] colonies, the effect was to preserve the jury trial only for monetary damage claims and not for "equitable" relief which was available in the discretion of the judge.In the case of Jeffrey Benjamin v. Savin Lake Service, Inc., the trial judge had ruled that Benjamin's equitable relief claim canceled his right to a jury trial and then, in a bench trial, found against Benjamin on the wrongful termination claim. This was, to put it mildly, a fundamental error and an abuse of the judge's power. It was summarily overturned by the unanimous Court of Appeals panel. The panel noted that simply claiming alternative equitable damages did not waive Benjamin's right to a jury trial on his legal claim. Furthermore, he did not voluntarily and knowingly "waive" the constitutional right (which he had formally demanded in a timely manner), by failing to formally object to and appeal the Court's pre-trial order. The latter had summarily determined that the case was a "non-jury matter."