Landgraf v. USI Film
Products case brief summary
511 U.S. 244
511 U.S. 244
CASE SYNOPSIS: Petitioner
requested a writ of certiorari from an order of the United States
Court of Appeals for the Fifth Circuit, which held that petitioner
was not entitled to a jury trial under the Civil Rights Act of 1991,
42 U.S.C.S. § 1981a(a), because the Act was not retrospectively
applicable to a Title VII case that was pending on appeal. Respondent
had committed sexual discrimination but petitioner was without
equitable relief.
FACTS: Petitioner was not entitled to a jury trial in a Title VII case against respondent for sexual harassment even though respondent had committed the discrimination and petitioner was left without an equitable remedy. During appeal, the Act became effective and granted the right to a jury trial for cases under Title VII of the Civil Rights Act of 1964, 42 U.S.C.S. § 2000e et seq. The Supreme Court had to decide whether to apply the law in effect at the time the discriminatory conduct occurred, or the law that became effective during the appeal.
HOLDING:
The Court affirmed the circuit court's determination and did not give the Act a retrospective application.
ANALYSIS:
The Court reviewed congressional intent on whether the Act was retrospective. The Court determined that no express or implied intent had been given. The Court examined the presumption against statutory retroactivity. Further, because a retroactive interpretation would have caused a contrary reading in the Act, the Court affirmed the circuit court's refusal to grant retroactive operation.
CONCLUSION: The Supreme Court affirmed the holding that petitioner was not entitled to a jury trial in a Title VII sexual harassment case against respondent. Even though respondent had committed sexual harassment, the Civil Rights Act of 1991, granting the right to a jury trial, was not given retrospective operation to a pending appeal.
FACTS: Petitioner was not entitled to a jury trial in a Title VII case against respondent for sexual harassment even though respondent had committed the discrimination and petitioner was left without an equitable remedy. During appeal, the Act became effective and granted the right to a jury trial for cases under Title VII of the Civil Rights Act of 1964, 42 U.S.C.S. § 2000e et seq. The Supreme Court had to decide whether to apply the law in effect at the time the discriminatory conduct occurred, or the law that became effective during the appeal.
HOLDING:
The Court affirmed the circuit court's determination and did not give the Act a retrospective application.
ANALYSIS:
The Court reviewed congressional intent on whether the Act was retrospective. The Court determined that no express or implied intent had been given. The Court examined the presumption against statutory retroactivity. Further, because a retroactive interpretation would have caused a contrary reading in the Act, the Court affirmed the circuit court's refusal to grant retroactive operation.
CONCLUSION: The Supreme Court affirmed the holding that petitioner was not entitled to a jury trial in a Title VII sexual harassment case against respondent. Even though respondent had committed sexual harassment, the Civil Rights Act of 1991, granting the right to a jury trial, was not given retrospective operation to a pending appeal.
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