Law School Case Brief
Feltner v. Columbia Pictures Tv - 523 U.S. 340, 118 S. Ct. 1279 (1998)
The general rule is that monetary relief is legal, and an award of statutory damages may serve purposes traditionally associated with legal relief, such as compensation and punishment. Nor is a monetary remedy rendered equitable simply because it is not fixed or readily calculable from a fixed formula. And there is historical evidence that cases involving discretionary monetary relief were tried before juries. Accordingly, U.S. Const. amend. VII provides a right to a jury trial where a copyright owner elects to recover statutory damages.
Respondent Columbia Pictures Television, Inc., terminated agreements licensing several television series to three television stations owned by petitioner Feltner after the stations' royalty payments became delinquent. When the stations continued to broadcast the programs, Columbia sued Feltner and others for, inter alia, copyright infringement. Columbia won partial summary judgment as to liability on its copyright infringement claims and then exercised the option afforded by § 504(c) of the Copyright Act (Act) to recover statutory damages in lieu of actual damages. The District Court denied Feltner's request for a jury trial, and awarded Columbia statutory damages following a bench trial. The Ninth Circuit affirmed, holding that neither § 504(c) nor the Seventh Amendment provides a right to a jury trial on statutory damages.
Was Feltner entitled to have a jury determine the amount of statutory damages for infringement?
The court held that the Seventh Amendment to the United States Constitution provided Feltner a right to a jury trial for a determination of the amount of statutory damages sought by respondent. After concluding that no jury trial right arose from § 504(c) itself, the court found that historically, in England and America, copyright infringement suits seeking monetary damages were tried in courts of law, and thus before juries. In addition, the court recognized the general rule that monetary relief was legal in nature, and such relief was not rendered equitable simply because it was not fixed or readily calculable. Moreover, the jury trial right extended to calculation of the actual amount of statutory damages to be awarded.
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