The Ninth Circuit can add another notch to its "Supreme Court reversal belt."
On Monday, the Court reversed a Ninth Circuit judgment dismissing a copyright heir's claim on the basis of laches. Finding the court's judgment in error, the Supreme Court reversed and remanded.
Raging Bull Copyright Ownership
The present case deals with the copyrights related to the "Raging Bull" film starring Robert De Niro, based on the life of boxing champion Jake LaMotta. Frank Petrella, LaMotta's friend, joined LaMotta in telling the champ's life story, which resulted in two screenplays, and one book. The only work at issue here is one screenplay written in 1963, which credits Petrella as the sole author.
The two assigned their rights, which resulted in the lawful making of the film, but Petrella died in 1981, with his copyrights reverting to his heirs, regardless of any previous assignments. Ten years later, Petrella's daughter, Paula Petrella, renewed the copyright. Seven years after renewing the copyright, in 1988, Petrella informed MGM that she owned the copyright to the screenplay. For two years, Petrella and MGM exchanged letters through their attorneys about possible copyright infringement.
Laches and the Copyright Act
In 2009, Petrella initiated a copyright infringement action against MGM, seeking injunctive and monetary relief. Under the Copyright Act, she understood that she was only entitled to relief for infringing acts that occurred within the past three years, and did not seek relief for any infringing acts that occurred more than three years prior.
MGM filed a motion for summary judgment invoking the doctrine of laches, claiming that Petrella's delay resulted in prejudice, and was unreasonable. The Ninth Circuit affirmed.
Supreme Court Analysis
The question before the Supreme Court was whether the doctrine of laches was applicable to the Copyright Act, where Congress had already accounted for delay when it crafted a statue of limitations. The Court held that it was not, stating "in face of a statue of limitations enacted by Congress, laches cannot be invoked to bar legal relief." That Petrella's delay was financially motivated was irrelevant because she had informed MGM had that she held the copyright. The Court also noted that adjustments for delay could be made in the relief granted, but should not preclude her claims at the outset.
Justice Breyer dissented because he found MGM's laches arguments convincing. The case is now remanded back to the Ninth Circuit. Let's hope they get it right the second time around.