Feltner v. Columbia Pictures Television, Inc.
Headline: Copyright statutory damages must be decided by juries; Court reverses judge-only awards, allowing copyright owners or alleged infringers to demand a jury to set the amount of statutory damages.
Holding: The Court holds that the Seventh Amendment guarantees a jury trial when a copyright owner seeks statutory damages, including a jury’s right to determine the amount of those statutory damages.
- Allows parties to demand a jury to set statutory copyright damages.
- Prevents judges from unilaterally fixing statutory-damages amounts when jury is demanded.
- Will change trial planning and potential damage exposure in copyright suits.
Summary
Background
A television station owner who ran three stations continued airing shows after his licenses ended. The TV network sued for copyright infringement and chose statutory damages instead of actual losses. The trial judge refused a jury on damages, found 440 infringements, ruled the violations willful, and set damages at $20,000 per act (totaling $8.8 million). The court of appeals affirmed that a judge alone could set statutory damages.
Reasoning
The Supreme Court first examined the statute and found it does not clearly grant a jury the power to set statutory damages. Because the statute was silent, the Court turned to the Seventh Amendment. The majority reviewed history and found that copyright damages and similar money claims were traditionally tried by juries. The Court concluded that monetary statutory awards are the kind of legal relief for which the Constitution preserves a jury trial. Therefore, if a party demands it, a jury must decide liability issues relating to statutory damages and must determine the amount awarded.
Real world impact
The ruling means copyright owners and defendants can insist on a jury to decide statutory damages and the amount claimed. Judges cannot unilaterally fix those awards when a jury is properly demanded. The case was sent back for further proceedings consistent with the decision, so specific damage totals may change on rehearing.
Dissents or concurrances
Justice Scalia agreed with the outcome but argued the statute itself can fairly be read to allow jury decision, avoiding the constitutional question.
Opinions in this case:
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