## Facts

- C. Elvin Feltner, Jr., through Krypton International Corporation, acquired three television stations that broadcast television series licensed from Columbia Pictures Television, Inc.
- The stations became delinquent in royalty payments; negotiations to restructure the debt failed.
- Columbia terminated the license agreements in October 1991, but the stations continued broadcasting Columbia’s programs after termination.
- Columbia sued Feltner, Krypton, the stations, related entities, and certain officers for copyright infringement and sought injunctive relief, impoundment, damages (actual or statutory), and attorney’s fees.
- The district court granted partial summary judgment for Columbia on liability.
- Columbia elected statutory damages under 17 U.S.C. § 504(c), which sets a damages range and states that damages are awarded as “the court considers just,” with adjustments for willful or innocent infringement.
- Feltner demanded a jury trial on statutory damages; the district court denied the request, conducted a bench trial, and awarded statutory damages.
- The Ninth Circuit affirmed, concluding that neither § 504(c) nor the Seventh Amendment entitled Feltner to a jury trial on statutory damages.

## Issues

1. Whether 17 U.S.C. § 504(c) itself provides a right to a jury trial on statutory damages in a copyright infringement action.
2. Whether the Seventh Amendment requires a jury trial on issues pertinent to statutory damages under § 504(c), including the amount of the award.

## Decision

- The Supreme Court reversed the Ninth Circuit.
- The Court held that § 504(c) does not create a statutory right to a jury trial because it does not mention juries and uses “the court” to assign decisionmaking authority.
- The Court held that the Seventh Amendment guarantees a right to a jury trial on all issues pertinent to statutory damages under § 504(c), including determination of the amount, when a party properly demands a jury.
- The case required jury determination of statutory damages rather than judicial assessment in a bench proceeding.

## Legal Principles

- Statutory silence regarding juries does not defeat a Seventh Amendment jury-trial right when the action and remedy are analogous to suits at common law.
- For Seventh Amendment purposes, copyright infringement actions seeking monetary relief are analogous to actions at law historically tried to juries.
- Statutory damages under § 504(c) are legal relief; the jury’s role includes setting the amount within the statutory range and deciding facts bearing on the statutory amount (such as willfulness) when properly submitted.
- Although § 504(c) assigns authority to “the court” as a matter of statutory interpretation, the Constitution requires a jury to determine statutory damages upon a timely jury demand.

## Conclusion

The Court held that § 504(c) does not itself grant a jury-trial right, but the Seventh Amendment requires a jury to decide all issues bearing on copyright statutory damages, including the amount, when a party demands a jury.


Feltner v. Columbia Pictures Television, Inc., 523 U.S. 340 (1998)