Curtis v. Loether
United States Supreme Court
415 U.S. 189 (1974)
Curtis (plaintiff), an African American woman, brought suit against the Loethers (defendants), alleging that they had refused to rent her an apartment because of her race, in violation of § 812 of Title VIII. In addition to requesting damages, Curtis filed for a preliminary injunction to prevent the Loethers from renting the apartment pending disposition of the trial, and the court granted the motion. When Curtis found housing five months later, she allowed the court to release the injunction. In the Loethers answer, they demanded a jury trial, and the court denied that demand, holding that jury trials were neither authorized by Title VIII nor required under the Seventh Amendment. At trial, the court found that the Loethers had violated Title VIII and awarded Curtis $250 in punitive damages, but no actual damages or attorneys fees. The court of appeals reversed on the jury trial issue, and the United States Supreme Court granted certiorari.
Rule of Law
Holding and Reasoning (Marshall, J.)