Docket nos. 12-1315 Argument Oral argument Date 2014 | Citations 572 U.S. ___ (more) Opinion announcement Opinion announcement | |
Full case name Paula Petrella, Petitioner v. Metro-Goldwyn-Mayer, Inc., et al. Prior history Petrella v. Metro-Goldwyn-Mayer, 695 F.3d 946 (9th Cir. 2012). , cert. granted, 570 U. S. ___ (2013) | ||
Petrella v. MGM is a United States Supreme Court copyright decision in which the Court held, 6-3, that the equitable defense of laches is not available to copyright defendants in claims for damages.
Contents
Background
After retiring from the boxing ring, Jake LaMotta collaborated with his friend Frank Petrella to write a story about his career. That collaboration resulted in three copyrighted works:
In 1976, LaMotta and Petrella assigned the copyrights in their works, including renewal rights, to Chartoff-Winkler Productions, Inc., which assigned them in 1978 to United Artists Corporation, which later became a subsidiary of Metro-Goldwyn-Mayer. In 1980, as a result, MGM released (and registered copyright in) the film Raging Bull, which achieved popular and critical success.
Petrella died in 1981, during the initial terms in the three original works. Because of the ruling in Stewart v. Abend, the renewal rights reverted to his heirs. In 1991, Petrella's daughter Paula sought to renew the copyrights, but was only able to timely file with respect to the 1963 screenplay. In 1998, her attorney informed MGM of that status, and advised that exploitation of any derivative work, including the film, infringed on that copyright.
After several years of negotiations and litigation threats, Petrella commenced a copyright infringement claim against MGM in the United States District Court for the Central District of California, seeking monetary and injunctive relief, but only with respect to the immediately preceding three years as provided by 17 U.S.C. § 507(b). MGM moved for summary judgment, arguing that, under the equitable doctrine of laches, Petrella’s 18-year delay in filing suit, was unreasonable and prejudicial to MGM. The District Court granted MGM’s motion, holding that laches barred Petrella’s complaint. The judgment was later affirmed by the United States Court of Appeals for the Ninth Circuit, citing its previous jurisprudence in the matter.
Because of conflicting opinions in the various Circuit courts on the subject, the Supreme Court granted certiorari in order to resolve the matter.
Opinion of the Court
The Ninth Circuit's ruling was reversed and remanded. In a 6-3 ruling, Ginsburg J. declared that laches cannot be invoked as a bar to pursuing a claim for damages brought within §507(b)’s three-year window. However, in extraordinary circumstances, laches may, at the very outset of litigation, curtail the relief equitably awarded.
Laches has a restricted scope in law, because:
In dissent, Breyer J stated that laches was available as a remedy because, when Congress enacted a uniform statute of limitations for copyright claims in 1957, it did not indicate that it also sought to bar the operation of laches. "The Copyright Act is silent on the subject. And silence is consistent, not inconsistent, with the application of equitable doctrines."
Commentary and Analysis
Writing for Forbes, Daniel Fisher wrote that artists and heirs will now need to be vigilant as to how their copyrights are being exploited, while film studios and other developers of derivative works will need to be diligent in examining the title to copyrighted material.
Subsequent Developments
MGM settled with Petrella in 2015.