Curtis v. Loether Case Brief

Why is the case important?

“Curtis (Petitioner) brought a civil rights action under Section 812 of the Civil Rights Act of 1968 (Act) claiming that Loether and others who were white (Respondents) refused to rent an apartment to her because of her race. The district court held that a jury trial was not authorized and denied a jury trial. The United States Court of Appeals for the Seventh Circuit reversed on the jury trial issue.
Synopsis of Rule of Law. The Seventh Amendment entitles either party to demand a jury trial in a civil rights action.”

Facts of the case

Question

Whether the Civil Rights Act of 1968 or the Seventh Amendment requires a jury trial upon demand of one of the parties in an action for damages and injunctive relief?

Answer

Yes. Judgment is affirmed. The Seventh Amendment entitles either party to demand a jury trial in an action for damages in federal court under the Civil Rights Act of 1968. The right to a jury trial applies to actions enforcing statutory rights. The Act requires a jury trial upon demand, if the statute creates legal rights and remedies, enforceable in an action for damages in courts of law. In the instant case, the damages action under Section 812 is an action to enforce legal rights within the meaning of the right to a jury trial. The damages action is basically an action in tort, which is a recognized action at common law. Further, the traditional relief sought is the traditional form offered in the court of law. When Congress provides for enforcement of statutory rights in an ordinary civil action in the district courts, a jury trial must be available if the action involves rights and remedies of the sort typically enforced by law. Petitioner’s policy argument is that a jury trial may delay the disposition of damages actions, and that there is the possibility of jury prejudice. The court found these arguments to have merit. However, these considerations are insufficient to overcome the command for a jury trial in the Seventh Amendment. Therefore, the Defendants’ demand for jury trial should be granted.

Conclusion

“Any controversy in an amount exceeding $20 is protected by the Seventh Amendment.  The court held that a damage suit under 42 U.S.C.S. § 3612 was an action to enforce “”legal rights”” within the meaning of the Seventh Amendment . Petitioner’s action under the Civil Rights Act of 1968 was a tort action

  • therefore the Seventh Amendment applied to preserved respondents’ right to a jury trial, where the statute created legal rights and remedies, enforceable in an action for damages in the ordinary courts of law. Moreover, the relief sought, actual and punitive damages, was the traditional form of relief offered in the courts of law.”
    • Case Brief: 1974
    • Petitioner: Curtis
    • Respondent: Loether
    • Decided by: Burger Court

    Citation: 415 US 189 (1974)
    Argued: Dec 4 – 5, 1973
    Decided: Feb 20, 1974