Under Curtis v. Loether, 415 U.S. 189, 194 (1974), the right to a jury trial in a statutory action depends on the presence of "legal rights and remedies." In Curtis, 415 U.S., at 195-196, the Courtruled that the availability of actual and punitive damages made a statutory antidiscrimination action resemble a legal tort action more than any equitable action. The Court made explicit that we did not "go so far as to say that any award of monetary relief must necessarily be `legal' relief." Id., at 196. Although monetary damages might cause some statutory actions to resemble tort suits, the presence of monetary damages in this duty of fair representation action does not make it more analogous to a legal action than to an equitable action.