In Curtis v. Loether, 415 U.S. 189 (1974), the Court held the Seventh Amendment applicable to private damages suits in federal courts brought under the housing discrimination provisions of the Civil Rights Act of 1968. The Court rejected the argument that Jones & Laughlin held the Seventh Amendment inapplicable to any action based on a statutorily created right even if the action was brought before a tribunal which customarily utilizes a jury as its factfinding arm. Instead, the Court concluded that NLRB v. Jones & Laughlin Steel Corp., 301 U.S. 1 (1937) upheld "congressional power to entrust enforcement of statutory rights to an administrative process or specialized court of equity free from the strictures of the Seventh Amendment." 415 U.S., at 194-195.