Petrella v. Metro-Goldwyn-Mayer, Inc.
May 19, 2014
Case #: 12-1315
Ginsburg, J., delivered the opinion of the Court, in which Scalia, Thomas, Alito, Sotomayor, and Kagan. JJ., joined. Breyer, J., filed a dissenting opinion, in which Roberts, C. J., and Kennedy, J., joined.
Full Text Opinion: http://www.supremecourt.gov/opinions/13pdf/12-1315_ook3.pdf
Civil Procedure: Where Congress has provided a statute of limitations under Section 507(b) of the Copyright Act, the defense of laches is only available in extraordinary circumstances.
Copyright law permits an author's heir to renew a copyright in a work despite the fact that the author had assigned rights to the work to a third party. To continue using the work, the third party must renew assignment rights with the heir.
Respondent acquired renewal rights of a screenplay. The owner of the screenplay died, and his renewal rights reverted to his heirs, Petitioner. Petitioner renewed those rights in 1991. In 1998, Petitioner advised Respondent of copyright violations, and sued in 2009 seeking damages and injunctive relief. The trial court granted summary judgment to Respondent because laches barred the suit; Petitioner had waited too long. The Ninth Circuit agreed.
The Supreme Court disagrees. In the Copyright Act, Congress provides a three-year statute of limitations for infringement claims. Prior to passage of this act, courts borrowed state law limitation periods and permitted the defense of laches. However, the Court today reminds us that laches was originally, and still is, intended to fill gaps in the law, not to override legislation. Allowing plaintiffs to wait and see whether an infringement merits litigation will prevent a flood of "sue soon, or forever hold your peace" suits. Also, estoppel remains in place to protect defendants who have relied on misleading copyright holders. However, the Court also notes that laches remains available to counter equitable relief in extraordinary copyright cases.