May 19, 2014

Supreme Court Decides Petrella v. Metro-Goldwyn-Mayer, Inc.

On May 19, 2014, the Supreme Court of the United States decided Petrella v. Metro-Goldwyn-Mayer, Inc., No. 12-1315, holding that the equitable defense of laches cannot be used to bar a claim for damages due to copyright infringement that is brought within the three-year statute of limitations.

The case involved the rights to a screenplay of the classic 1980 film Raging Bull, based on the life of boxing champion Jake LaMotta. LaMotta and friend Frank Petrella chronicled LaMotta's life in a screenplay, the copyright of which was registered in 1963. In 1976, LaMotta and Petrella assigned their rights in the screenplay to Metro-Goldwyn-Mayer (MGM). Petrella died one year after the 1980 release of the movie. His daughter, Paula, renewed the copyright in 1991. (When an author who previously assigned his copyright dies before the renewal period for the copyright, the assignee may continue to use the original work only if the author's successor transfers the renewal rights to the assignee; otherwise, the author's successor may renew the copyright without regard to the prior assignment.) Paula told MGM in 1998 that she believed MGM's sale of the movie (a derivative work from the screenplay) infringed her copyright, but she did not sue MGM for infringement until 2009.

MGM moved for summary judgment under the doctrine of laches, arguing that Paula's 18-year delay in bringing suit after obtaining her rights was unreasonable and prejudicial, and barred her claims entirely. The district court granted the motion, and the Ninth Circuit affirmed.

The Supreme Court reversed and remanded, concluding that laches cannot be invoked to bar copyright-infringement claims for damages that are brought within the three-year limitation period in the Copyright Act (17 U.S.C. § 507(b)). The Court held that Congress's decision to provide a three-year period in which to bring lawsuits could not be overridden by an equitable doctrine such as laches, as the doctrine of laches was a device used by courts of equity to deal with a circumstance where there was no prescribed limitation period.

While laches cannot be used to bar a plaintiff's claim if it is within the limitation period, the Court went on to rule that, in extraordinary circumstances, laches could be invoked to curtail the plaintiff's requested remedy—for example, a court could refuse to order complete destruction of an infringing film if the plaintiff unreasonably delayed in bringing suit and the defendant expended a lot of money in the interim to produce and copy the film.

Justice Ginsburg delivered the opinion of the Court, in which Justices Scalia, Thomas, Alito, Sotomayor, and Kagan joined. Justice Breyer filed a dissenting opinion, in which Chief Justice Roberts and Justice Kennedy joined.

Download the Opinion of the Court

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