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Golan v. Holder

Summarized by: 

Date Filed: 01-18-2012
Case #: 10-545
GINSBURG, J., delivered the opinion of the Court, in which ROBERTS, C. J., and SCALIA, KENNEDY, THOMAS, and SOTOMAYOR, JJ., joined. BREYER, J., filed a dissenting opinion, in which ALITO, J., joined. KAGAN, J., took no part in the consideration or decision of the case.
Full Text Opinion: http://www.supremecourt.gov/opinions/11pdf/10-545.pdf

Copyright: Congress did not exceed its authority under the Copyright Clause of the Constitution by removing works from the public domain previously unprotected by U.S. copyright laws.

In 1994, Congress enacted section 514 of the Uruguay Round Agreements Act (URAA), providing U.S. copyright protection to foreign works which had previously been unprotected in the U.S. and part of the public domain. The petitioners (various conductor, musicians, and publishers) brought an action against the U.S. Attorney General (Holder) arguing that Congress exceeded its authority under the Copyright Clause by enacting section 514 and removing works from the public domain. The district court granted Holder’s motion for summary judgment and the Tenth Circuit Court of Appeals affirmed. Petitioner’s argued that the Copyright Clause’s limitation to the lifespan of a copyright prevents the removal of a work from the public domain and therefore Congress exceeded its authority. The Supreme Court held that Congress did not exceed its authority because the Copyright Clause does not prevent works from being removed from the public domain and historical interpretation of the Copyright Clause allows for the protection of previously unprotected works. Since Congress did not exceed its authority under the Copyright Clause by enacting section 514 of URAA, the judgment of the Tenth Circuit was AFFIRMED.