In the case of C. Elvin Feltner, Jr. v. Columbia Pictures Television, Inc., 1997, the U.S Supreme Court ruled that a copyright owner can seek damages from an infringer without first registering their work with the Copyright Office. The dispute arose when Columbia Pictures sued Feltner for airing episodes of several television shows without obtaining licenses or paying royalties to them as they held copyrights on these programs. Initially, a district court awarded statutory damages to Columbia based on each infringed episode rather than per series and this decision was upheld by Ninth Circuit Court of Appeals stating that defendants do not have right to jury trial under Copyright Act's statutory damages provision. However, upon reaching Supreme Court it reversed lower courts' decisions ruling that Seventh Amendment provides right to jury trial when infringement leads to statutory damage awards and also clarified that award should be calculated per work (series) rather than individual episodes within those works.

In the dissenting opinion for C. Elvin Feltner, Jr. v. Columbia Pictures Television, Inc., Justice Scalia disagreed with the majority's interpretation of statutory damages provisions in copyright law as allowing a jury trial right under the Seventh Amendment. He argued that these provisions were not analogous to common-law actions traditionally decided by juries and thus did not trigger this constitutional protection. Instead, he viewed them as more akin to equitable remedies typically determined by judges rather than juries due to their discretionary nature and purpose of discouraging wrongful conduct rather than compensating actual loss or harm suffered by plaintiffs.