SCOTUSblog: Petrella v. Metro-Goldwyn-Mayer, Inc.
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.