Edward M. Steck, Respondent v. the Colorado Fuel and Iron Company, Appellant

Summary

The Court held that whether an action is referable for compulsory reference is determined solely by the complaint; a counterclaim in the answer that involves a long account cannot make a non‑referable action referable. Accordingly, the motion for reference was denied and the lower court's order was reversed. Justice Andrews, dissenting, argued that the counterclaim involving a long account makes the action referable and that the constitutional right to a jury trial does not preclude such a reference.