Perttu v. Richards

The Seventh Amendment requires a jury trial on Prison Litigation Reform Act (PLRA) exhaustion when that issue is intertwined with the merits of a claim that falls under the Seventh Amendment. Chief Justice John Roberts authored the 5-4 majority opinion of the Court. PLRA exhaustion operates as a standard affirmative defense subject to the usual practice under the Federal Rules of Civil Procedure. The usual practice requires factual disputes regarding legal claims to go to a jury, even when a judge could ordinarily resolve such questions independently. Because Congress legislates against the backdrop of established common-law adjudicatory principles, and because the PLRA remains silent on whether judges or juries should resolve exhaustion disputes, this silence constitutes strong evidence that courts should follow the usual practice of sending factual disputes to juries when they are intertwined with the merits. At the time Congress enacted the PLRA in 1996, well-established precedent required that factual disputes intertwined with Seventh Amendment claims go to juries. Two lines of cases support this principle. First, in cases involving both legal and equitable claims, Beacon Theatres established that judges may not resolve equitable claims first if doing so could prevent legal claims from reaching a jury, because judicial discretion must preserve jury trial rights wherever possible. Second, in subject matter jurisdiction cases like Smithers v. Smith and Land v. Dollar, courts may not resolve factual disputes when those disputes are intertwined with the merits, as this would risk deciding the controversy’s substance without ordinary trial procedures, including the right to a jury. When the PLRA was enacted, the usual federal court practice across various contexts involved resolving factual disputes intertwined with the merits at the merits stage itself. Justice Amy Coney Barrett authored a dissenting opinion, joined by Justices Clarence Thomas, Samuel Alito, and Brett Kavanaugh, arguing that the majority’s statutory interpretation contravenes basic principles because the PLRA’s silence cannot confer a jury trial right, and that the jury trial right under the Seventh Amendment does not depend on factual overlap between threshold issues and the merits.