Curtis v. Loether

Brief Fact Summary.

After Defendants refused to rent an apartment to Plaintiff, a black woman, because of her race, Plaintiff filed suit against Defendants for violating Title VII. Defendants demanded a jury trial, which was denied by the district court.

Synopsis of Rule of Law.

The Seventh Amendment guarantees the right to a jury trial for parties seeking damages under Title VII.

Facts.

Curtis (Plaintiff), a black woman, brought a lawsuit against the Loethers (Defendants), who are white, after Defendants refused to rent an apartment to her solely because she was black. Their refusal to rent an apartment to her was in violation of § 812 of Title VII because they discriminated against her simply because of her race. In her complaint, Plaintiff not only sought damages but also sought injunctive relief. After a hearing, the district court granted the preliminary injunction; however, once Plaintiff obtained other housing five months later, the injunction was suspended with Plaintiff’s consent. The case went to trial on the issue of damages. In their answer, Defendants demanded a jury trial. The district court denied Defendants’ jury request because the jury trial was neither authorized nor mandatory under the Seventh Amendment. After trial, the district court ruled that Defendants discriminated against Plaintiff because of her race and therefore violated the Title VII. The district court awarded Plaintiff $250 in punitive damages. Subsequently, the Court of Appeals reversed with respect to the jury trial issue. The United States Supreme Court granted certiorari to resolve the issue.

Issue.

Does the Seventh Amendment guarantee the right to a jury trial for parties seeking damages under Title VII?

Held.

Yes. The Seventh Amendment guarantees the right to a jury trial for parties seeking damages under Title VII. According to the Seventh Amendment, the right of a jury trial is guaranteed for lawsuits at common law where the value in dispute exceeds $20. Since Title VII creates a legal right and a remedy of damages and Plaintiff sought to have a legal right enforced and money damages, the Seventh Amendment guarantees the right to a jury trial. Therefore, United States Supreme Court affirmed the ruling of the Court of Appeals.

Discussion.

The Seventh Amendment preserves the right to a jury trial. With respect to newly created statutory rights, however, the Court must decide whether the Seventh Amendments guarantees the right to a jury trial for parties seeking a remedy under these newly created statutory rights. In deciding whether there is a right to a jury trial for such claims, the Court must determine whether the claim is similar to one that would have been brought in equity or at law for claims that would have been brought when the Seventh Amendment was drafted in 1791. In addition, the Court looks to whether the claim is seeking monetary damages or an injunction.