SW Legal studies in Business

Equity and Law Issues in Same Case May Be Tried Separately

Nevada high court held that in a case that contained both matters of equity and of law, the trial court could split the matters and hold a bench trial on the equity issues and then later have a jury trial on the matters of law.

Topic Court Procedure
Key Words

Equitable Claims; Legal Claims; Bifurcated Trial

C A S E   S U M M A R Y

Awada is a casino game developer. He entered into an agreement with Shuffle Master, a maker of casino games and equipment. The two got into a fight when Shuffle learned that Awada had given another company rights to use certain games that Shuffle thought were under its control. The parties sued each other. The claims involved equitable matters and matters of law. The trial judge held a bifurcated trial, holding a bench trial first on the equitable claims and then had a trial on the legal claims. An appeal followed, claiming, in part, that the trial should not have been split.


Affirmed. The right to a jury trial does not apply to the ability of a court to address the equitable issues raised in an action before allowing a jury to address the legal issues. Hence, the trial court could have a bifurcated trial, addressing the equity issues first, then having a trial on the legal issues. There was no need to address both sets of issues in the same proceeding. The conclusions that were reached in both trials were correct and are upheld.


Awada v. Shuffle Master, Inc., 173 P.3d 707 (Sup. Ct., Nev., 2007)

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