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:

  1. Compare to causes of action under English law
  2. 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.