## Facts

- A Black woman alleged that white apartment owners refused to rent her an apartment because of her race, violating the Fair Housing Act.
- She sued under the Act’s private civil action provision seeking injunctive relief and punitive damages, later adding compensatory damages.
- The district court issued a preliminary injunction preventing the apartment from being rented to others pending trial; it was later dissolved with her consent after she obtained other housing.
- The case proceeded to trial on actual and punitive damages.
- Defendants timely demanded a jury trial, which the district court denied.
- After a bench trial, the court found racial discrimination, found no actual damages, awarded punitive damages, and denied attorney’s fees and costs.

## Issues

1. Whether the Fair Housing Act’s private civil action provision authorizes or requires a jury trial when a party demands one.
2. Whether the Seventh Amendment requires a jury trial on the damages issues in an action seeking damages and injunctive relief for housing discrimination under the Act.

## Decision

- The Supreme Court affirmed the court of appeals.
- The Seventh Amendment entitles either party to a jury trial, on demand, in a federal-court action for damages under the Act’s private civil action provision.
- The Act’s silence on juries does not defeat the constitutional jury right where the claim seeks legal remedies (damages).
- The presence of requested injunctive relief does not eliminate the jury right as to the legal (damages) issues.

## Legal Principles

- The Seventh Amendment jury guarantee extends to statutory causes of action when the statute creates legal rights and legal remedies tried in the ordinary courts of law.
- A claim for compensatory and punitive damages is the traditional form of legal relief and is treated as an action “at law” for Seventh Amendment purposes.
- An action for damages under the Fair Housing Act’s private enforcement provision is analogous to common-law tort actions and therefore falls within the Seventh Amendment’s protection.
- When legal and equitable relief are joined in one action, the jury right applies to the legal issues; equitable claims do not negate that right.
- Policy concerns about delay or possible juror bias cannot override the Seventh Amendment’s command where it applies.

## Conclusion

A private Fair Housing Act suit seeking damages is an action at law, so either party is constitutionally entitled to a jury trial on the damages issues upon timely demand, even if the complaint also seeks injunctive relief.


Curtis v. Loether, 415 U.S. 189 (1974)