19 May 2014

Law in Plain English: Petrella v. Metro-Goldwyn-Mayer, Inc.

This is one in a series of posts designed to describe court decisions in plain English. For more detail and background on the legal issues, see the link to the case below. For similar posts, click here.

SCOTUSblogPetrella v. Metro-Goldwyn-Mayer, Inc.

Why did the Supreme Court take this case? In this case, the Ninth Circuit held that the defense of laches is available in copyright cases. In the Fourth Circuit, there is no laches at all. If a copyright suit is brought within the statute of limitations, it may go forward. In the Eleventh Circuit, "there is a strong presumption that a plaintiff's suit is timely if it is filed before the statute of limitations has run. Only in the most extraordinary circumstances will laches be recognized as a defense." Even if laches is found, "laches serves as a bar only to the recovery of retrospective damages, not to prospective relief."  In the Second Circuit, laches is available as a bar to injunctive relief but not to money damages. In the Sixth Circuit, laches is available in only "the most compelling of cases." So-called "circuit splits" are perhaps the most common way cases make it to the Supreme Court.

Argument: Jan 21 2014 (Aud.)

Background: In 2009, Paula Petrella filed an action for copyright infringement, unjust enrichment and accounting against Metro-Goldwyn-Mayer, Inc., and others. According to Petrella, the defendants infringed her purported interest in a book and two screenplays that together allegedly formed the basis for the 1980 motion picture Raging Bull. Petrella's father Frank, who wrote the 1963 screenplay, died in 1981. In 1991, Petrella successfully renewed the copyright in the 1963 screenplay. Because her father died within 28 years of the original copyright, the renewal rights vest in the author’s heirs (Paula) regardless of whether the author assigned the renewal term of copyright to a third-party prior to his death. Petrella renewed the copyright and knew of her claims in 1991, but did not file a lawsuit until January 2009. Because of the three-year statute of limitations prescribed by Congress in 17 U.S.C. § 507(b), Ms. Petrella claimed damages only for the copyright infringement occurring between 2006 and 2009.

The District Court granted summary judgment in favor of the defendants, holding that Petrella's claims are barred by the equitable defense of laches. The Ninth Circuit affirm.

Issue: The question before the Court is whether the nonstatutory defense of laches is available without restriction to bar all remedies for civil copyright claims filed within the three-year statute of limitations prescribed by Congress, 17 U.S.C. § 507(b).

Holding: In a 6-3 decision, the Supreme Court ruled that laches cannot be invoked as a bar to Petrella’s pursuit of a claim for damages brought within §507(b)’s three-year window. By permitting a successful plaintiff to gain retrospective relief only three years back from the time of suit, the copyright statute of
limitations itself takes account of delay.
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