Law School Case Brief
Curtis v. Loether - 415 U.S. 189, 94 S. Ct. 1005 (1974)
The Seventh Amendment applies to actions enforcing statutory rights, and requires a jury trial upon demand, if the statute creates legal rights and remedies, enforceable in an action for damages in the ordinary courts of law.
Petitioner filed suit pursuant to § 812 of the Civil Rights Act of 1968, 42 U.S.C.S. § 3612, seeking injunctive relief and actual and punitive damages due to respondents' refusal to rent an apartment to her because of her race. Respondents requested a jury trial, which was denied by the district court.
Is a proper demand for a jury trial by either party valid under the Seventh Amendment?
Any controversy in an amount exceeding $20 is protected by the Seventh Amendment. The court held that a damage suit under 42 U.S.C.S. § 3612 was an action to enforce "legal rights" within the meaning of the Seventh Amendment. Petitioner's action under the Civil Rights Act of 1968 was a tort action; therefore the Seventh Amendment applied to preserved respondents' right to a jury trial, where the statute created legal rights and remedies, enforceable in an action for damages in the ordinary courts of law. Moreover, the relief sought, actual and punitive damages, was the traditional form of relief offered in the courts of law.
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