In Tull v. United States, 481 U.S. 412, 422 (1987), the availability of damages again played a critical role in determining the right to a jury trial. In an environmental suit by the Government for injunctive relief and a civil penalty, both an equitable public nuisance action and a legal action in debt seemed appropriate historical models. The Court decided between them by noting that only the courts of law could award civil penalties. See id., at 422-425. The Court stated in Tull, "our search is for a single historical analog, taking into consideration the nature of the cause of action and the remedy as two important factors." Id., at 422, n. 6.