Feltner v. Columbia Pictures

Case Name: Feltner v. Columbia Pictures Television, Inc. 523 U.S. 340 (1998)

Facts: Feltner owned Krypton International Corporation which had a license to rebroadcast several television shows owned by Columbia Pictures. Feltner fell behind in payments to Columbia. Columbia asked Feltner to cease broadcasting these shows and Feltner ignored their order. Columbia brought suit against Feltner for copyright infringement.

Procedural History: The District Court did not allow Feltner a jury trial, and ruled that he owed Columbia $8.8 million for infringement of their copyright. The Ninth Circuit Court affirmed this ruling. Feltner appealed on the belief that the Seventh Amendment guaranteed him a right to a jury trial.

Issue: Did the lower courts err in not allowing Feltner the right to have his case decided by a jury trial? It did not meet the requirements in the statute for a jury trial, but did it meet requirements for the Seventh Amendment's guaranteed right to a jury trial?

Judgment: The Supreme Court ruled statutory damages were covered under the guarantees of the Seventh Amendment's right to a jury trial. They reversed the decision of the lower courts and ordered the trial back to court for the jury to determine the actual amount of statutory damages.

Reasoning: The Court did not find a statutory right to a jury trial in order to recover statutory damages in copyright cases. They had to hold this ruling against the Constitution and the Seventh Amendment. They ruled there were analogous cases in England dating back to 1710 making this a Seventh Amendment case under the English Common Law of 1790 precedent. They also referenced American Cases of juries determining statutory damages for copyright infringement dating back to 1783.

Concurrence: Justice Scalia concurred with the ruling. He believed the case should have had a jury decide statutory damages, but did not believe the jury was constitutionally required because it did not need to be tested that far. He believed statutes up until that point allowed for the jury to decide these damages. The word “court” had been interpreted by the majority of the Court to mean “judge” whereas Scalia believed this term could include juries.

Comments: I find myself believing that the jury trial eventually granted to Feltner was constitutionally correct. Historical analogues provided more evidence for the need of a jury trial than precedence, and the interpretation of the word “court” to be taken to mean juries was too vague to provide a concrete ruling. After the trial was ruled back to lower courts Feltner probably wished he would have lost his appeal. The lower jury courts ruled he owed $31.68 million instead of the original $8.8 million. When Feltner tried to appeal to the Supreme Court it was denied and the $31.68 million award was upheld.