Curtis v. Loether

Supreme Court of the United States, 1974. 415 U.S. 189, 94 S.Ct. 1005, 39 L.Ed.2d 260.

Facts: Plaintiff claimed defendants discriminated against her by refusing to rent her an apartment because she was black; plaintiff sought punitive and compensatory damages. Defendants moved to have a jury trial; plaintiff objected.

Procedure: "District Court held that a jury trial was neither authorized by Title VIII nor required by the Seventh Amendment and denied the jury request." "The Court of Appeals reversed on the jury trial issue... the court concluded essentially that the Seventh Amendment gave respondents the right to a jury trial in this action, and therefore interpreted the statute to authorize jury trials so as to eliminate any question of its constitutionality."

Issues: Did the claim warrant a jury trial? Was the Court of Appeals correct?

Holding: Yes and Yes.

Reasoning: "The relief sought here-actual and punitive damages-is the traditional form of relief offered in the courts of law." "We have often found the Seventh Amendment applicable to causes of action based on statutes."

Concurring/Dissenting Opinions: None presented in our text.

Analysis: Basically, they found that the defendant was seeking legal relief and not equitable relief, and that that distinction is the heart of the Seventh Amendment's interpretation. Also, they made it clear that the Seventh Amendment was not designed to freeze the common law as it was in 1791, declaring everything enacted after as something else.