Term: 2013
Docket: 12-1315
Petrella v. Metro-goldwyn-mayer, Inc.
- Pro
12-1315 PETRELLA V. MGM, INC. DECISION BELOW: 695 F.3d 946 CERT. GRANTED 10/1/2013 QUESTION PRESENTED: The Copyright Act expressly prescribes a three--year statute of limitations for civil copyright claims. 17 U.S.C. § 507(b). The three-year period accrues separately for each act of infringement, even if it is one of a continuing series of acts of infringement. The federal courts of appeals have divided 3-2-1 over whether the nonstatutory defense of laches can bar a civil copyright suit brought within the express three-year statute of limitations. Three circuits forbid any application of laches or restrict the remedies to which it can apply. Two other circuits strongly disfavor laches and restrict it to exceptional circumstances. The Ninth Circuit not only does not restrict laches or the remedies to which it can apply, but has also adopted a presumption in favor of applying laches to continuing copyright infringements. The question presented is: Whether the nonstatutory defense of laches is available without restriction to bar all remedies for civil copyright claims filed within the three-year statute of limitations prescribed by Congress, 17 U.S.C. § 507(b). LOWER COURT CASE NUMBER: 10-55834, 10-55853
The case of Petrella v. Metro-Goldwyn-Mayer, Inc., 2013 revolved around copyright infringement and the doctrine of laches (a legal principle that bars those who take too long to assert a legal right). Paula Petrella, whose father Frank Petrella had written works underlying the movie "Raging Bull", sued MGM for copyright infringement in 2009. She claimed ownership rights due to her father's death before the original term of his copyright expired. However, MGM argued that she waited too long to file her lawsuit as she became aware of her potential claim by 1991 but didn't sue until eighteen years later. The Supreme Court ruled in favor of Petrella with a six-to-three decision stating that laches cannot be invoked as a bar to pursuing damages claims brought within the three-year window set out under Copyright Act’s statute-of-limitations provision.
In the dissenting opinion for Petrella v. Metro-Goldwyn-Mayer, Inc., Justice Breyer argued that laches should be applicable in copyright infringement cases even when they fall within the Copyright Act's three-year statute of limitations. He emphasized that allowing plaintiffs to delay litigation until potential damages are maximized could lead to unfairness and hardship for defendants who have invested heavily into a work unaware of any outstanding claims. Furthermore, he pointed out that evidence may become lost or difficult to retrieve over time, complicating legal proceedings unnecessarily. Therefore, he disagreed with the majority's decision which held laches cannot preclude damages incurred within the statutory period.
