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Keywords

lawsuitappealtrialmotionunjust enrichmentjury trial

lawsuittrialmotionadoptionjury trial

Related Cases

Kim v. Dean, 133 Wash.App. 338, 135 P.3d 978, 24 IER Cases 1347

Facts

Tae Yon Kim filed a lawsuit against Jeffrey and Deborah Dean, alleging that they promised him a share of the proceeds from the sale of their business, Spectrum Print & Mail Services, Ltd. After being terminated shortly after the sale, Kim sought recovery under unjust enrichment and promissory estoppel. The trial court denied the Deans' motion to strike Kim's jury demand, leading to a jury trial where Kim was awarded $500,000.

In December 2001, Tae Yon Kim filed a lawsuit against Jeffrey Dean, Deborah Dean and the Dean marital community. The complaint alleged that Kim had worked for the Deans' business, Spectrum Print & Mail Services, Ltd., and that the Deans had promised Kim that he would receive a portion of the proceeds upon the sale of Spectrum to another company.

Issue

Does the Washington Constitution guarantee a right to a jury trial for a promissory estoppel claim?

Is there a right to jury trial under the Washington Constitution for a promissory estoppel claim?

Rule

The Washington Constitution provides a right to trial by jury only for civil actions that are purely legal in nature, not for those that are purely equitable.

Accordingly, there is a right to trial by jury for a civil action that is purely legal in nature, but not one that is purely equitable.

Analysis

The court determined that Kim's promissory estoppel claim was fundamentally equitable, as it arose from a promise that lacked consideration and was rooted in the equitable doctrine of reliance. Since such claims were treated as equitable in 1889, the court concluded that there was no constitutional right to a jury trial for this type of claim.

Because the doctrine of promissory estoppel did not exist at the time of the adoption of the Washington Constitution in 1889, we must determine whether a claim cognizable today as promissory estoppel would have been considered a legal claim or an equitable claim in 1889 and whether such a claim would have been tried by a jury or the court.

Conclusion

The Court of Appeals reversed the trial court's decision to allow a jury trial and remanded the case for a nonjury trial.

We reverse the superior court's order denying the Deans' motion to strike Kim's demand for a jury and remand for further proceedings.

Who won?

The Deans prevailed in the appeal because the court ruled that Kim's claim did not entitle him to a jury trial, which was the basis for reversing the lower court's decision.

We reverse the judgment and remand for a nonjury trial.

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