Term: 2009
Docket: 08-103
Reed Elsevier, Inc., Et Al., v. Irvin Muchnick Et Al.
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08-103 REED ELSEVIER, INC. V. MUCHNICK DECISION BELOW: 509 F.3d 116 LIMITED TO THE FOLLOWING QUESTION: Does 17 U.S.C. §411(a) restrict the subject matter jurisdiction of the federal courts over copyright infringement actions? JUSTICE SOTOMAYOR TOOK NO PART. ORDER OF APRIL 2, 2009: DEBORAH JONES MERRITT, ESQ., OF COLUMBUS, OHIO, IS INVITED TO BRIEF AND ARGUE THIS CASE, AS AMICUS CURIAE, IN SUPPORT OF THE JUDGMENT BELOW. CERT. GRANTED 3/2/2009 QUESTION PRESENTED: 1. Whether the usual power of lower courts to approve a comprehensive settlement releasing claims that would be outside the courts' subject matter jurisdiction to adjudicate, confirmed in Matsushita Elec. Indus. Co. v. Epstein, 516 U.S. 367 (1996), was eliminated in copyright infringement actions by 17 U.S.C. § 411(a). 2. Whether the Second Circuit erred by ignoring the assurance in New York Times Co. v. Tasini, 533 U.S. 483, 505 (2001), that the problem of compromised electronic news archives could be remedied by "[t]he Parties (Authors and Publishers [entering] into an agreement allowing continued electronic reproduction of the Authors' works . . . and remunerating authors for their distribution." LOWER COURT CASE NUMBER: 05-5943, 06-0223
The U.S. Supreme Court case Reed Elsevier, Inc., et al., v. Irvin Muchnick et al., 2009 revolved around a dispute between freelance authors and publishers over the copyright of articles in electronic databases. The plaintiffs (freelance authors) argued that the defendants (publishers) had infringed their copyrights by reproducing their work electronically without permission or compensation. A settlement was reached but some freelancers objected on grounds it unfairly favored those who had registered copyrights over those who hadn't, leading to an appeal questioning whether Section 411(a) of the Copyright Act restricted courts from hearing claims involving unregistered works. The Supreme Court ruled that Section 411(a)'s registration requirement is not jurisdictional, meaning district courts may hear copyright cases even if registration has not been made - thus allowing for settlements like this one to proceed despite objections based on non-registration status.
In the dissenting opinion for Reed Elsevier, Inc., et al. v. Irvin Muchnick et al., Justice Thomas argued that § 411(a) of the Copyright Act is a jurisdictional requirement and thus, noncompliance with it should result in dismissal of copyright infringement claims. He contended that this section's registration requirement was not merely procedural but rather directly linked to a court’s ability to hear copyright cases as it defines which infringements are actionable under federal law. Therefore, he disagreed with the majority's view that § 411(a) does not restrict a federal court’s subject-matter jurisdiction over infringement claims involving unregistered works. Furthermore, he pointed out inconsistencies in how courts have interpreted similar statutory requirements and called for clearer guidelines on distinguishing between claim-processing rules and jurisdictional prerequisites.
