Curtis v. Loether

Brief Fact Summary. The Petitioner, Curtis (Petitioner), sued the Respondent, Loether (Respondent), alleging their failure to rent her an apartment was due to her race. Petitioner sued pursuant to Section:812 of the Civil Rights Act of 1968 (the Act), which entitled either party to demand a jury trial. When Respondent requested a jury trial, the District Court denied the request.

Synopsis of Rule of Law. The Seventh Amendment of the United States Constitution (Constitution) does apply 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.

Facts. Petitioner brought a suit against Respondents for their alleged discrimination in refusing to rent an apartment to her because of her race. Petitioner’s complaint sought injunctive relief and punitive damages and was later amended to include compensatory damages. The injunctive relief was granted and then dissolved when Petitioner had obtained other housing. The trial commenced on the issues of actual and punitive damages. Respondents made a timely request for a jury trial and the District Court denied the request. The Petitioner was awarded $250 in punitive damages. On appeal, the Court of Appeals reversed on the jury trial issue.

Issue. Whether the Act or the Seventh Amendment of the Constitution requires a jury trial upon demand by one of the parties in an action for damages and injunctive relief under Section 812 of the Act.

Held. The Seventh Amendment entitled either party to demand a jury trial in an action for damages in the federal courts under Section: 812 of the Act. Affirmed.

Discussion. Section 812 of the Act authorizes private plaintiffs to bring civil actions to redress violations of Title VIII, the fair housing provision of the Act.
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 trial right, the jury trial must be available if the action involves rights and remedies of the sort typically enforced in an action at law. The right sought here, actual and punitive damages, is the traditional form of relief that courts of law offer.