Bringe v. Collins
335 A.2d 670, 274 Md. 338 (1975)
Rule of Law:
The Seventh Amendment right to a jury trial in civil cases is not applicable to state court proceedings through the Fourteenth Amendment. Under the Maryland Constitution, the right to a civil jury trial is preserved only when the amount in controversy exceeds $500, and this right is waived if not timely and properly demanded.
Facts:
- Wayne C. Collins was the landlord of a property.
- John Bringe was the tenant residing at Collins's property under a lease.
- The term of the lease expired.
- Bringe allegedly continued to occupy the property after the expiration of the lease term.
Procedural Posture:
- In an initial action, landlord Wayne C. Collins sued tenant John Bringe in the District Court of Maryland to recover possession of real estate.
- The District Court entered a judgment for restitution of the possession of the premises in favor of Collins.
- Bringe appealed to the Circuit Court for Prince George’s County, which affirmed the district court's judgment.
- The Court of Appeals of Maryland (the highest court) then denied Bringe’s petition for a writ of certiorari in that initial action.
- Following a U.S. Supreme Court decision in an unrelated case, Bringe initiated a new, separate proceeding in the Circuit Court for Prince George’s County.
- In this new action, Bringe sought a declaratory judgment that the Maryland eviction statute was unconstitutional and an injunction to prevent his eviction.
- The Circuit Court denied all relief sought by Bringe.
- Bringe (appellant) appealed the Circuit Court's denial to the Court of Special Appeals (the intermediate appellate court).
- The Court of Appeals of Maryland granted a writ of certiorari before the Court of Special Appeals rendered a decision.
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Issue:
Is a tenant in a landlord's action to recover possession of real estate, where no monetary value is claimed, unconstitutionally denied a right to a jury trial under the Seventh Amendment of the U.S. Constitution and Article XV, § 6 of the Maryland Constitution?
Opinions:
Majority - Eldridge, J.
No, the tenant is not unconstitutionally denied a right to a jury trial. The court reasoned on three grounds: 1) The Seventh Amendment's guarantee of a jury trial in civil cases does not apply to state court proceedings, as the Supreme Court has consistently held it is not incorporated by the Fourteenth Amendment's Due Process Clause. The Supreme Court's decision in Pernell v. Southall Realty only applied to the District of Columbia, a federal jurisdiction, and did not overrule this long-standing precedent. 2) Article XV, § 6 of the Maryland Constitution only preserves the right to a jury trial in civil proceedings "where the amount in controversy exceeds the sum of five hundred dollars." Since neither party in the underlying eviction action claimed money damages or asserted that the right of possession had a monetary value over $500, the state constitutional right did not attach. 3) Even if a right to a jury trial had existed, Bringe waived it by failing to file a timely demand for one as required by Maryland District Rule 343.
Analysis:
This decision solidifies the long-standing principle that the Seventh Amendment's right to a civil jury trial is not a fundamental right applicable to the states through the Fourteenth Amendment. It clarifies for Maryland practitioners that the state constitution's monetary threshold for a jury trial is a strict requirement, even in possessory actions where value is not inherently quantified. The ruling also serves as a strong reminder of the doctrine of waiver, emphasizing that constitutional rights, including the right to a jury trial, can be lost through the failure to adhere to established procedural rules for invoking them.
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