Pearson Education, Inc. v. Joel Thomas Almgren, 685 F.3d 691

Publishers sued Almgren for copyright infringement after he sold unlicensed solution manuals and earned about $5,000 in gross profits.
Almgren filed Chapter 7 bankruptcy in Minnesota; bankruptcy court struck the publishers’ jury-trial demand and awarded $14,250 in statutory damages (non-dischargeable).
Bankruptcy court denied the publishers’ request for over $90,000 in attorney’s fees; court found the litigation strategy unreasonable given lack of real damages.
District Court affirmed, holding publishers waived jury trial by filing proofs of claim and approved the fee-denial determination.
The court analyzes whether a creditor’s non-dischargeability action preserves a jury right and whether Stern v. Marshall affects Katchen/Langenkamp.
Court ultimately affirms both the denial of a jury trial on damages and the denial of attorney’s fees.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Jury right in non-dischargeability damages	Feltner grants jury for statutory damages.	Filing proofs of claim in bankruptcy forfeits jury on related matters per Langenkamp.	No Seventh Amendment right; jury demand-struck.
Effect of Stern on Katchen/Langenkamp	Stern undermines continued viability of Katchen/Langenkamp.	Stern does not invalidate those precedents where claims affect estate proceedings.	Stern does not undermine; apply same rule.
Damages determination in bankruptcy context	Damages should be decided by a jury.	Damages tied to claims-allowance process; determined without jury.	Damages adjudicated without a jury.
Attorney’s fees award standard	Fees justified to deter willful infringement.	Court’s equitable discretion supported by factors; no abuse.	No abuse; denial affirmed.

Feltner v. Columbia Pictures Television, Inc., 523 U.S. 340 (U.S. 1998) (jury right for statutory damages generally; bankruptcy context limits it)
Katchen v. Landy, 382 U.S. 323 (U.S. 1966) (claims against estate trigger equitable bankruptcy treatment; no jury)
Granfinanciera, S.A. v. Nordberg, 492 U.S. 33 (U.S. 1989) (distinguishes when jury right applies in bankruptcy proceedings)
Langenkamp v. Culp, 498 U.S. 42 (U.S. 1990) (creditor filing a claim becomes part of the equity process; no jury right)
Stern v. Marshall, 564 U.S. --- (U.S. 2011) (distinguishes core claim resolutions from claims processing; bankruptcy court cannot always decide counterclaims)
In re CBI Holding Co., 529 F.3d 432 (2d Cir. 2008) (applies Langenkamp to non-dischargeability actions)
In re Kennedy, 108 F.3d 1015 (9th Cir. 1997) (non-dischargeability ruling may render monetary judgment without jury)
Billing v. Ravin, Greenberg & Zackin, P.A., 22 F.3d 1242 (3d Cir. 1994) (Langenkamp guide on fee-shifting in bankruptcy)
In re Hallahan, 936 F.2d 1496 (7th Cir. 1991) (core proceedings typically do not involve jury trial)