Petrella v. MGM, Inc.

PETITIONER: Paula Petrella
RESPONDENT: Metro-Goldwyn-Mayer, Inc., et al.
LOCATION: United States District Court for the Central District of California

DOCKET NO.: 12-1315
DECIDED BY: Roberts Court (2010-2016)
LOWER COURT:

CITATION: 572 US (2014)
GRANTED: Oct 01, 2013
ARGUED: Jan 21, 2014
DECIDED: May 19, 2014

ADVOCATES:
Mark A. Perry - on behalf of the respondents
Nicole A. Saharsky -
Stephanos Bibas - on behalf of the petitioner

Facts of the case

After Jake LaMotta retired from boxing, he and Frank Peter Petrella (F. Petrella) created two screenplays and a book based on LaMotta's life. These works were registered with the United States Copyright Office in 1963, 1973, and 1970, respectively. In 1976, LaMotta and F. Petrella signed a written agreement that granted the exclusive rights to the book and the screenplays to Chartoff-Winkler Productions, Inc, which in turn assigned those rights to a subsidiary of Metro-Goldwyn-Mayer Studios, Inc. (MGM), United Artists Corporation. In 1980, United Artists Corporation registered a copyright for the film "Raging Bull" based on LaMotta and F. Petrella's work. When F. Petrella died in 1981, which was still within the original 28-year period of the copyright, his renewal rights passed to his heirs.

In 1991, Paula Petrella (Petrella), the daughter of F. Petrella, filed an application for the renewal of copyright rights on the 1963 screenplay. In 1998, Petrella's attorney contacted MGM and asserted that Petrella had obtained the rights to the screenplay and its derivative works, which included the movie "Raging Bull," and that MGM was infringing on those rights. MGM argued that the 1963 screenplay was a collaboration between LaMotta and F. Petrella, so MGM retained the rights to the screenplay under the agreement with LaMotta. MGM also argued that there was no "substantial similarity of protectable elements" between the 1963 screenplay and the film. In 2009, Petrella sued MGM for copyright infringement, and the federal district court granted summary judgment for MGM under the doctrine of laches, which prevents a legal claim from being enforced if a long delay in filing the claim adversely affected the defendant's ability to fight the claim. The U.S. Court of Appeals for the Ninth Circuit affirmed.

Question

Does the doctrine of laches apply without restriction to civil copyright claims that are within the bounds of the federal three-year statute of limitations on such cases?

Media for Petrella v. MGM, Inc.

Audio Transcription for Oral Argument - January 21, 2014 in Petrella v. MGM, Inc.

Audio Transcription for Opinion Announcement - May 19, 2014 in Petrella v. MGM, Inc.

Justice Ginsburg has the opinion of the Court this morning in case 12-1315, Petrella v. Metro-Goldwyn-Mayer.

The Copyright Act provides in Section 507(b), ?No civil action shall be maintained under the Act unless it is commenced within three years after the claim accrued.

This case presents the question whether the equitable defense of laches, which means unreasonable prejudicial delay in commencing suit, may bar relief on the copyright infringement claim within Section 507(b)'s three-year limitations period.

The allegedly infringing work in this case is the motion picture ?Raging Bull,? based on the life of boxing champion Jake LaMotta.

LaMotta and his friend, Frank Petrella, collaborated on a screenplay about the boxer's life copyrighted in 1963.

LaMotta and Petrella thereafter assigned away all their rights in the screenplay including renewal rights.

Metro-Goldwyn-Mayer, MGM, acquired those rights and in 1980 released the film ?Raging Bull? which it continuous to market today.

Frank Petrella died before the expiration of the initial copyright term.

Under the Act, his renewal right reverted to his daughter, Paula Petrella.

Thereafter, as Frank is dead, I will call Paula Petrella.

Under the governing law, MGM may use a 1963 screenplay only if Petrella transferred her rights to MGM.

She did not.

Petrella renewed the 1963 copyright in 1991.

Seven years later, she advised MGM that its exploitation of Raging Bull infringed upon her copyright.

She threatened suit.

MGM told her the film was unprofitable.

Some nine years after that in January 2009, when it appeared that Raging Bull was making money, Petrella sued MGM for infringement seeking monetary and injunctive relief.

The District Court affirmed by the Ninth Circuit held the doctrine of laches barred her claim in its entirety.

We granted review because Federal Courts of Appeals are divided on this issue and we now reverse.

Section 507(b) all agree, bars relief of any kind for conduct occurring prior to the three-year limitations period, in this case, prior to 2006.

But for alleged infringement occurring within the three-year window, courts are not at liberty to jettison Congress' judgment on the timeliness of suit.

Laches, we hold, cannot be invoked to block the recovery of damages as to equitable relief including an injunction stopping future infringement and in accounting for the infringes' profits.

In extraordinary circumstances, laches may bar at the very threshold certain relief plaintiff seeks.

Examples are set out in our opinion, but in this case no extraordinary circumstances appeared to exist.

There is nothing untold about waiting to see whether an infringer is making money so that litigation is worth the candle.

Nevertheless, if Petrella prevails on the merits of her infringement claim, her delay on any detrimental reliance on it by MGM can be taken into account in shaping appropriate injunctive relief and in assessing the profits attributable to the infringement.

The Government as a friend of the Court suggests for example that MGM, if it shows detrimental reliance on Petrella's in action, might be allowed to continue marketing Raging Bull as a derivative work upon paying a reasonable royalty to Petrella.

For reasons more completely developed in the Court's opinion, the judgment of the Court of Appeals for the Ninth Circuit is reversed and the case is remanded for further proceedings consistent with this Court's opinion.

Justice Breyer has filed a dissenting opinion in which the Chief Justice and Justice Kennedy joined.

Sarah from Law Aspect

Hi there, would you like to get such a paper? How about receiving a customized one? Check it out https://goo.gl/9aavBA