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Curtis v. Loether

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Brief Fact Summary.

Plaintiff claims race discrimination in violation of Title VIII of the Civil Rights Act of 1968 and sued defendants. Defendants wanted a jury trial, but their request was denied by the trial court.

Synopsis of Rule of Law.

The Seventh Amendment entitled either party to demand a jury trial in an action for damages under Title VIII of the Civil Rights Act of 1968.

Points of Law - Legal Principles in this Case for Law Students.

An action for money damages was the traditional form of relief offered in the courts of law.

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Facts.

Plaintiff Curtis accused Defendants Loethers of refusing to rent her an apartment in violation of Title VIII of the Civil Rights Act of 1968. Plaintiff Curtis also requested a preliminary injunction to enjoin Defendants from renting the unit until the dispute was resolved, which the court granted. Plaintiff Curtis found housing five months later and allowed the court to release the injunction. Defendants requested a jury trial in their  which the court denied, holding that it was not required under Title VIII or the Seventh Amendment. At trial the court found Defendant Loethers in violation answerof Title VIII and awarded $250 in punitive damages only, no actual damages or attorneys fees. The court of appeals reversed on the jury-trial issue, and the Supreme Court of the United States granted certiorari.

Issue.

Does the Seventh Amendment entitle either party to demand a jury trial in an action for damages under Title viii of the civil Rights Act of 1968?

Held.

Yes, the Seventh Amendment entitles either party to demand a jury trial in an action for damages under Title viii of the civil Rights Act of 1968. The decision of the appellate court is affirmed.

Dissent.

Justice Circuit Judge Rives

The original punitive damages award of $3,000,000 and the remitted award are both unconstitutional. The award violated Defendant Curtis’ Seventh Amendment rights. The trial judge gave no reasons as to why he believed the jury’s award was not based on prejudice, but it clearly was and therefore cannot be remedied through remittitur. Curtis’ motion for a new trial should be granted.

Discussion.

  1. Precedent establishes that the Seventh Amendment is applicable to causes of action arising from statutes if the statute creates new legal rights and remedies that are enforceable in court. This is the case here.
  2. § 812 of Title VIII provides a framework for enforcing legal rights and bringing a damage action. Therefore the Seventh Amendment applies.
  3. While a jury trial has its pitfalls, like racial bias and being time consuming, there are procedural safeguards in place that allow the court to deal with the issues.
  4. The decision of the appellate court is affirmed.

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