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Civil Procedure Keyed to Glannon

Curtis v. Loether

Facts

Curtis (Plaintiff), a black woman, brought a lawsuit against the Loethers (Defendants), who are white, after Defendants refused to rent an apartment to her solely because she was black. Their refusal to rent an apartment to her was in violation of § 812 of Title VII because they discriminated against her simply because of her race. In her complaint, Plaintiff not only sought damages but also sought injunctive relief. After a hearing, the district court granted the preliminary injunction; however, once Plaintiff obtained other housing five months later, the injunction was suspended with Plaintiff’s consent. The case went to trial on the issue of damages. In their answer, Defendants demanded a jury trial. The district court denied Defendants’ jury request because the jury trial was neither authorized nor mandatory under the Seventh Amendment. After trial, the district court ruled that Defendants discriminated against Plaintiff because of her race and therefore violated the Title VII. The district court awarded Plaintiff $250 in punitive damages. Subsequently, the Court of Appeals reversed with respect to the jury trial issue. The United States Supreme Court granted certiorari to resolve the issue.

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