Juries Ruled Out in Small Claims Case Appeals

The state Supreme Court ruled Tuesday that defendants who lose in small claims courts have no right to a jury trial when they appeal to higher courts.

The court unanimously found that while losing small claims defendants have a right to a new trial before a Superior Court judge, they have no right to demand that a jury review their claims.

The justices noted that the small claims system, set up by the Legislature in 1921, is supposed to be informal and should resolve problems quickly. The courts have jurisdiction over disputes involving $1,500 or less.

Municipal or Justice Court judges preside over the cases. There are no juries, lawyers are not allowed to represent the parties and there are no rules regarding what evidence may be admitted.

‘Expedited Procedures’

Writing for the court, Chief Justice Malcolm Lucas said rules governing small claims cases require “the same informal expedited procedures to be followed in the appeal. . . .”

“A jury trial would be manifestly inconsistent with the informal procedures required to be observed on appeal, such as the provision that the judge may consult witnesses informally and otherwise investigate the controversy,” the court said.

The case began when El Dorado Investors, owners of a Santa Cruz apartment complex, sued tenant Joseph Crouchman over damages to his apartment and unpaid rent. El Dorado won $1,526, including the $1,500 maximum that can be awarded in small claims court, plus a $26 cost of preparing the case.

When a Superior Court judge refused Crouchman’s demand for a jury trial, he appealed. A court of appeal also ruled against him in an opinion that Lucas quoted extensively.

Longstanding Rule

The question first arose in 1979 when a state Court of Appeal changed a longstanding rule by finding that defendants could demand a jury on appeal. In later years, separate courts of appeal reached different conclusions, and the high court agreed to decide the issue in 1985.

In a friend of the court brief, the state Department of Consumer Affairs urged the justices to “preserve the practical value of the California small claims system” and deny the right to jury trials. The agency and some judges worried that with 500,000 small claims cases annually, superior courts could face an even heavier burden if juries were allowed in appeals.

“I think judges feel that they can dispense justice quite adequately in these cases,” Alameda Superior Court Judge Roderic Duncan said. “In today’s litigious times, there just isn’t the time to give everyone a jury trial in every case.”