Supreme Court Decides the “Raging Bull” Case
The Supreme Court recently decided the case of Petrella v. Metro-Goldwyn-Mayer, Inc. (MGM), involving the question of how to decide if a copyright case is brought in a timely manner. The Copyright Act sets forth a three-year statute of limitations, yet a literal interpretation could allow lawsuits brought several years after the relevant events occurred.
Paula Petrella, the owner of a screenplay written in 1963, argues that it is the basis of the 1980 movie Raging Bull. Although Petrella was aware of the movie and its similarities to the screenplay, she did not file the copyright infringement lawsuit until 2009. Under the applicable statute of limitations, Petrella could recover damages for infringements (profits) since 2006. She could also obtain an injunction preventing future infringement without Petrella’s permission. MGM argued that because Petrella was aware of the movie and filed the lawsuit after so much time had passed from its release, her action should be wholly barred by laches.
The district court and the Ninth Circuit ruled in favor of MGM and dismissed the case. However, the Supreme Court reversed their decisions. The majority opinion was written by Justice Ginsburg.
The majority opinion focuses on the distinction between legal relief or damages and equitable relief such as injunctions. The Court found that because laches is an equitable doctrine, it cannot determine the timeliness of an action for damages. In other words, because the statute of limitations was established by federal statute in this case, the Court cannot rely on the doctrine of laches to dismiss a lawsuit that was brought within the statutorily set timeframe.
“MGM released Raging Bull more than three decades ago and has marketed it continuously since then,” Ginsburg said. “Allowing Petrella’s suit to go forward will put at risk only a fraction of the income MGM has earned during that period.”
With regard to the claim for injunctive relief, the Court stated that laches may bar the claim if “extraordinary circumstances” were present. No such extraordinary circumstances could be shown in this case to warrant barring Petrella’s claim.
Justice Breyer wrote a lengthy dissent and was joined by the Chief Justice and Justice Kennedy. The primary argument from the dissenters is that the delay in filing the lawsuit results in unfair loss of evidence. Breyer argued that lawsuits like this one seemed to him to be in fact inequitable, imposing unreasonable burdens on those who exploit copyrighted works. He believed the Court should take action to rein in the number of copyright lawsuits being brought after lengthy delays.
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Preamble to the Bill of Rights
Congress of the United States begun and held at the City of New-York, on Wednesday the fourth of March, one thousand seven hundred and eighty nine.
THE Conventions of a number of the States, having at the time of their adopting the Constitution, expressed a desire, in order to prevent misconstruction or abuse of its powers, that further declaratory and restrictive clauses should be added: And as extending the ground of public confidence in the Government, will best ensure the beneficent ends of its institution.