trial) (citations omitted); Bibbs v. Jim Lynch Cadillac, Inc., 653 F.2d 316, 318 (8th Cir.1981) (recognizing appropriateness of submitting all legal claims under § 1981 to jury and citing caselaw in accord). Further, the Supreme Court has made clear that 42 U.S.C. § 1981a, enacted by Congress in 1991, can be seen as creating a new cause of action that attaches an important new legal burden to engaging in discriminatory conduct in violation of Title VII, and that “‘if a complaining party seeks compensatory or punitive damages,’ the jury trial option must stand or fall with the attached damages provisions.” Landgraf v. U.S.I. Film Products, 511 U.S. 244, 114 S.Ct. 1483, 1505, 128 L.Ed.2d 229 (1994); see, e.g., Elbaz v. Congregation Beth Judea, Inc., 812 F.Supp. 802, 808 (N.D.Ill.1992) (<HOLDING>). Thus, the Decree, entered before the events
holding no remedy available under amended provisions of title vii for violations occurring prior to date of amendment november 21 1991 where discriminatory acts did not continue into the postamendment period holding that under section 510146 only a defendant sued after effective date of statute could seek interlocutory review holding that the doctrine of qualified immunity does not protect a government official who is sued in an official capacity under title vii because title vii does not impose personal liability holding that plaintiff who sued for damages under title vii after effective date of 1991 amendment was entitled to jury trial holding that the damages and jury trial provisions of the 1991 act apply to conduct occurring prior to the date of enactment