Curtis v. Loether
415 U.S. 189 (1974)
Facts:
- ¶, a black woman, alleges that r did not rent an apartment to her on the basis of race.
Procedural History:
- ¶ filed a claim for injunctive relief and compensatory & punitive damages.
- DC granted preliminary injunctive relief (not to rent the apt to someone else), which dissolved when ¶ found another apartment.
- r requested a jury trial, DC held that neither Title VIII nor the 7th Amendment authorized a jury trial
- After trail district judge found that the jury had discriminated against ¶ and awarded her $250 in punitive damages
- CA reversed on the jury trial issue
Affirmed
Contentions of parties:
¶: Violation of Title 8 of the Civil Rights Act which forbids discrimination on basis of race. It has an express private right of action.
Issue:
Whether the Civil Rights Act or the Seventh Amendment requires a jury trial on demand by one of the parties in an action for damages and injunctive relief §812.
Holding:
The Civil Rights Act or the Seventh Amendment allows a jury trial on demand by one of the parties in an action for damages and injunctive relief under §812 because it deals with legal rather than equitable rights.
Rule:
“When Congress provides for enforcement of statutory rights in an ordinary civil action in the district courts, where there is obviously no functional justification for denying the jury trail right, a jury trial must be available if the action involves rights and remedies of the sort typically enforced in an action at law.”
2-part test:
- Compare to causes of action under English law
- Type of remedies sought
Rule(s) of Law:
7th Amendment: right to jury trial
- 812
Reasoning:
Analogy with innkeepers, intentional torts,
The damages sought are compensation for an injury- sounds like a tort, which were heard in the law courts.
Case turns on the type of remedy sought- actual and punitive damages, available in a court of law.
If the only thing she had asked for was injunctive relief, she would not have a right to trial by jury because this type of relief could only be granted by an equity court.