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Copyright 3-year Statute of Limitations Trumps Laches Defense
May 20, 2014

PETRELLA v. METRO-GOLDWYN-MAYER, INC.

Frank Petrella wrote two screenplays and one book based on the life of boxing champion Jake LaMotta. One of the screenplays, registered in 1963, identifies Patrella as the sole author, written in collaboration with LaMotta. LaMotta and Patrella assigned their rights in the screenplay, including renewal rights, to Chartoff-Winkler Productions, Inc. in 1976, who in turn sold the motion picture rights to Metro-Goldwyn-Mayer, Inc. (MGM). MGM released the motion picture portrayal of Jake LaMotta in 1980: Raging Bull, staring Robert DeNiro and directed by Martin Scorcese.

Patrella died in 1981, during the original term of the copyright in the screenplay. Under the Supreme Court's decisions in Stewart v. Abend and Miller Music Corp. v. Charles N. Daniels, Inc., the right to renewal of the copyright reverted to Patrella's heirs, unencumbered by any of the assignments previously made by Patrella. Patrella's daughter filed a renewal of the copyright in the screenplay in 1991. In 1998, Patrella's daughter notified MGM that she owned the copyright in the screenplay, and any further exploitation of any derivative work, including Raging Bull, infringed that copyright. A copyright infringement suit was not filed, however, until 2009.

Section 507(b) of the Copyright Act establishes a three-year limitation on claims seeking relieve for copyright infringement. The 2009 complaint sought monetary and injunctive relief for violation of the copyright in the 1963 screenplay by using, producing, and distributing Raging Bull. However, the complaint only sought such relief for acts occurring on or after January 6, 2006—three years prior to filing the suit. MGM moved for summary judgment based on the doctrine of laches, asserting that even though the three-year limitations period set out in the statute had not run out, the claim was still barred under the equitable principle of laches— the 18 year delay between obtaining the copyright and filing suit was unreasonable and prejudicial. The district court granted the motion, which was affirmed by the Ninth Circuit Court of Appeals.

On ultimate appeal, the Supreme Court held that a copyright infringement suit seeking relief solely for conduct occurring within the limitations period cannot be precluded by a claim of laches, so long as the claim for damages is brought within the three-year window. The Court highlighted that laches is an equitable defense, applicable to claims for which the legislature has not provided a limitation period. Although laches may not preclude an infringement claim made within the limitations period, the Court made clear that other doctrines such as estoppel may limit the relief awarded.

The full opinion is availablehere.
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