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Curtis (P), a black woman, brought an action under Section 812 of the Civil Rights Act of 1968 under Title VIII for fair housing claims. P claimed that Loethers (D) refused to rent an apartment to her because of her race. P sought injunctive relief, compensatory damages, and punitive damages. Prior to the trial, the court issued an injunction from D renting the apartment to anyone pending a trial on the merits. The case went to trial on the issues of actual and punitive damages, and the injunction was dissolved with P’s consent. D made a timely request for a jury trial. The district court denied that request. The district court ruled for P. No actual damages were found, but $250 in punitive damages was awarded. The court of appeals reversed; the right to a jury trial was guaranteed by the Seventh Amendment. P appealed: The Seventh Amendment was inapplicable to statutory rights created by congressional enactment.

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