Petitioner alleged that respondents refused to rent her an apartment because of her race, in violation of Title VIII's fair housing provisions. She sought injunctive relief and punitive damages, and later also pursued actual damages. The district court initially granted preliminary injunctive relief, but that injunction was later dissolved after petitioner obtained other housing, leaving the damages issues for trial. Respondents timely demanded a jury, but the district court denied the request and tried the case without a jury.
Issue
Does the Seventh Amendment require a jury trial, upon demand, in a federal court action under § 812 of the Civil Rights Act of 1968 seeking actual and punitive damages, even though the cause of action is created by statute and may be joined with equitable relief?
Rule
The Seventh Amendment applies to actions enforcing statutory rights and requires a jury trial upon demand when the statute creates legal rights and remedies enforceable in an ordinary civil action in the district courts. A damages action under § 812 of Title VIII is legal in nature because it seeks the traditional legal remedies of actual and punitive damages; if legal and equitable claims are joined, the jury-trial right on the legal claim remains intact, including as to issues common to both claims.
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In federal district court in Chicago, Elena Ortiz sues Lakeshore Terrace Properties under a federal housing statute that creates a private cause of action for victims of disability discrimination. The statute authorizes temporary or permanent injunctions, actual damages, punitive damages up to a stated cap, costs, and attorney fees. Lakeshore timely demands a jury on Elena’s damages claim.
Is Lakeshore entitled to a jury trial on the damages claim?
Explanation. The governing rule is that the Seventh Amendment extends beyond 1791 common-law forms of action and applies to actions enforcing statutory rights when the statute creates legal rights and remedies enforceable in an ordinary action for damages in federal district court. Actual and punitive damages are traditional legal remedies. Therefore either party may demand a jury on that claim.