Feltner v. Columbia Pictures Television, Inc.

Columbia Pictures Television, Inc. (Columbia) (plaintiff) licensed several television series to C. Elvin Feltner (defendant), who owned Krypton International Corporation (Krypton) (defendant) and three television stations (defendants) in the Southeastern United States. After the defendants became delinquent in their royalty payments, Columbia entered into negotiations with them to restructure their debt. When the negotiations failed, Columbia terminated the license agreements. The stations continued broadcasting the television programs. Columbia sued for copyright infringement under the Copyright Act of 1976 (Copyright Act), 17 U.S.C. § 101 et seq. Columbia exercised its option under § 504(c) of the Copyright Act to recover statutory damages between $500 and $20,000, “as the court considers just,” in lieu of actual damages. Feltner sought a jury trial on the issue of statutory damages, which the federal district court denied. Instead, the district court held a bench trial and awarded statutory damages of $20,000 per act of infringement, resulting in a statutory damages award of $8,800,000 in Columbia’s favor. Feltner appealed to the United States Court of Appeals for the Ninth Circuit, which rejected his argument that he was entitled to a jury trial for statutory damages. The United States Supreme Court granted certiorari. Feltner argued that the Seventh Amendment gave him the right to a jury trial. Columbia opposed Feltner, arguing that statutory damages were equitable and that the Seventh Amendment therefore did not apply.