Feltner v Columbia Pictures Television, Inc.,

Case Name:
Feltner v. Columbia Pictures Television, Inc.

Case Cite:
523 U.S. 340

Facts of the case:
Columbia Pictures terminated licensing agreements to three television stations owned by Feltner after the stations' royalty payments became delinquent. The stations continued to broadcast the programs, so Columbia sued for copyright infringement. Columbia won partial summary judgment, and exercised § 504(c) of the Copyright Act of 1976 to recover statutory damages in lieu of actual damages.

Procedural Posture:
The District Court granted summary judgment to Columbia, Feltner's request for a jury trial, and awarded Columbia statutory damages following a bench trial. The Ninth Circuit affirmed, holding that neither § 504(c) nor the Seventh Amendment provides a right to a jury trial on statutory damages.

SCOTUS (Thomas, J.) reversed, holding that: (1) Copyright Act does not grant right to have jury assess statutory damages, but (2) Seventh Amendment provides right to jury trial on all issues pertinent to award of statutory damages in copyright infringement action, including amount itself. Although the statute is silent on the point, the Seventh Amendment provides a right to a jury trial, which includes a right to a jury determination of the amount of statutory damages. We therefore reverse.

Important Dicta:
The right to a jury trial includes the right to have a jury determine the amount of statutory damages, if any, awarded to the copyright owner. The court came to this answer after historical analysis of the Copyright Act and the Seventh Amendment, and reversed the lower courts determination that the Seventh Amendment did not provide for a right to a jury trial to determine statutory damages for copyright infringement. Although common law did not demonstrate an absolute need for jury trial here, it has been a consistent practice since the court of equity in England, and contrary to what Columbia was arguing, a jury determination is in fact necessary to preserve the substance of the common-law right of jury trials, and an award of statutory damages may serve purposes traditionally associated with legal relief, such as compensation and punishment.

Likely future importance or unanswered questions:
The use of a jury trial, if demanded, is required by the Constitution to determine statutory damages for breach of copyright infringement. This now mandates that a defendant have an opportunity to, if requested, have a jury determine the proper statutory amount, which may be lower or higher than what the plaintiff is seeking.

Critical Analysis:
The importance of the Seventh Amendment is pervasive throughout copyright law, and mandates that a jury trial on all issues pertinent to an award of statutory damages occur if requested.

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