523 U.S. 340 (1998)
Feltner v. Columbia Pictures Television is a landmark U.S.
Does the Seventh Amendment guarantee a right to a jury trial to determine the amount of statutory damages under 17 U.S.C. § 504(c) in a copyright infringement suit?
The Seventh Amendment preserves the right to a jury trial in "Suits at common law," which includes actions analogous to those tried at law in 18th-century England where legal remedies (such as damages) are sought. Courts apply a two-part test: (1) compare the statutory action to 18th-century actions to determine whether it is more analogous to cases at law or in equity, and (2) examine the remedy sought to determine whether it is legal or equitable, with the remedy inquiry being the more important. When an action is legal and seeks damages, the Seventh Amendment entitles the parties to a jury determination of all factual issues, including the amount of damages. Under 17 U.S.C. § 504(c), all issues pertinent to an award of statutory damages—including the amount within the statutory range and any willfulness determinations affecting that range—must be submitted to a jury upon proper demand.
Yes. The Supreme Court held that the Seventh Amendment guarantees a right to a jury trial to determine the amount of statutory damages under § 504(c) of the Copyright Act. The statute itself does not grant or deny a jury trial right, but the Constitution does.
Feltner cements the jury's constitutional role in assessing statutory damages in copyright cases and clarifies the methodology for Seventh Amendment analysis in modern statutory schemes. For litigators, it underscores the strategic stakes of jury demands when statutory damages are available—juries may award much more or less than a bench award within broad statutory ranges. For students, the case is a touchstone for understanding: (1) how courts analogize contemporary statutory actions to 18th-century forms; (2) the centrality of the remedy (legal vs. equitable) to Seventh Amendment questions; and (3) the limits of statutory phrasing like "the court may award" in displacing constitutional jury rights. Feltner has also been influential by analogy in other IP statutory damages regimes (e.g., under the Lanham Act's counterfeiting provisions), reinforcing that when legal damages are at issue, juries ordinarily assess the amount.