Feltner v. Columbia Pictures Television, Inc.
140 L. Ed. 2d 438, 118 S. Ct. 1279 (1998)
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Rule of Law:
The Seventh Amendment to the U.S. Constitution guarantees a right to a jury trial when a copyright owner elects to recover statutory damages under the Copyright Act, and this right includes having the jury determine the amount of damages awarded.
Facts:
- Petitioner C. Elvin Feltner owned Krypton International Corporation, which acquired three television stations.
- Respondent Columbia Pictures Television, Inc. licensed several television series to these stations, including 'Who’s the Boss' and 'T. J. Hooker'.
- Feltner's stations became delinquent in making their royalty payments to Columbia.
- After failed negotiations to restructure the debt, Columbia terminated the stations' license agreements in October 1991.
- Despite the termination of the agreements, Feltner's stations continued to broadcast Columbia's programs without authorization.
Procedural Posture:
- Columbia Pictures Television, Inc. sued C. Elvin Feltner in the United States District Court for copyright infringement.
- The District Court granted Columbia's motion for partial summary judgment on the issue of liability.
- Columbia elected to recover statutory damages under § 504(c) of the Copyright Act.
- The District Court denied Feltner's request for a jury trial on statutory damages, holding the issue would be resolved in a bench trial.
- After the bench trial, the judge found 440 acts of willful infringement and awarded Columbia $8,800,000 in statutory damages.
- Feltner (appellant) appealed to the U.S. Court of Appeals for the Ninth Circuit.
- The Court of Appeals affirmed the district court's ruling, holding that neither the statute nor the Seventh Amendment provides a right to a jury trial for statutory damages.
- The U.S. Supreme Court granted Feltner's petition for a writ of certiorari.
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Issue:
Does the Seventh Amendment grant a defendant the right to a jury trial on all issues, including the amount of damages, when a copyright owner elects to recover statutory damages under § 504(c) of the Copyright Act?
Opinions:
Majority - Justice Thomas
Yes. The Seventh Amendment provides a right to a jury trial on all issues pertinent to an award of statutory damages under § 504(c) of the Copyright Act, including the amount of the award itself. The Court first determined that the statutory language of § 504(c), which states damages are awarded as 'the court considers just,' refers to a judge, not a jury, and therefore does not statutorily grant a right to a jury trial. However, the Seventh Amendment preserves the right to a jury trial for suits analogous to common law actions from 18th-century England. Historically, actions for damages in copyright infringement cases were considered actions at law, tried before juries. The remedy of statutory damages, which serves purposes of compensation and punishment, is a legal remedy, not an equitable one. Therefore, the constitutional right to a jury trial applies. This right extends to the determination of the amount of damages, as this was historically a core function of the jury in common law.
Concurring - Justice Scalia
Justice Scalia concurred in the judgment, agreeing that the case should be reversed, but would have resolved the case on statutory grounds to avoid the constitutional question. He argued that the term 'court' in § 504(c) is ambiguous and can be interpreted to include both the judge and jury. Citing the doctrine of constitutional avoidance, which directs courts to choose a reasonable interpretation of a statute that avoids constitutional problems, he concluded that § 504(c) can and should be read to permit a jury trial. This interpretation is supported by the history of the statute's predecessors, which involved 'actions on the case' that were historically tried by juries. By interpreting the statute this way, the Court could grant the right to a jury trial without needing to hold the statute unconstitutional under the Seventh Amendment.
Analysis:
This decision clarifies a significant aspect of Seventh Amendment jurisprudence, particularly as it applies to statutory rights. The Court affirmed that the historical test for the right to a jury trial applies even when a modern statute grants discretionary monetary relief. By extending the jury's role to the determination of the amount of statutory damages, the ruling reinforces the jury as the finder of fact for legal remedies. This holding impacts not only copyright law but also other federal statutes providing for statutory damages, suggesting that if the underlying cause of action is analogous to a suit at common law, a jury must determine liability and the amount of the award.
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