Petrella v. Metro-Goldwyn-Mayer, Inc.

134 S.Ct 1962 (2014)

Purchase the Printed Copy at bsmsphd.com

Nature of the Case

To access this section all you need to do is click here and register.

Facts

The infringing work, in this case, is the motion picture, Raging Bull. After retiring from the ring, LaMotta worked with his longtime friend, Frank Petrella, to tell the story of the boxer’s career. Their venture resulted in three copyrighted works: two screenplays, one registered in 1963, the other in 1973, and a book, registered in 1970. In 1976, Frank Petrella and LaMotta assigned their rights in the three works, including renewal rights, to Chartoff-Winkler Productions. Two years later, Metro (D) acquired the motion picture rights to the book and both screenplays, rights stated by the parties to be “exclusive and forever, including all periods of copyright and renewals and extensions thereof.” In 1980, D released, and registered a copyright in, the film Raging Bull. Frank Petrella died in 1981, during the initial terms of the copyrights in the screenplays and book. Frank Petrella’s renewal rights reverted to his heirs, P, who could renew the copyrights unburdened by any assignment previously made by the author. P engaged an attorney who, in 1991, renewed the copyright in the 1963 screenplay. Because the copyrights in the 1973 screenplay and the 1970 book were not timely renewed, the infringement claims, in this case, rest exclusively on the screenplay registered in 1963. P is now sole owner of the copyright in that work. In 1998, seven years after filing for renewal of the copyright in the 1963 screenplay, P’s attorney informed D that P had obtained the copyright to that screenplay. During the next two years, counsel exchanged letters in which D denied the validity of the infringement claims, and P repeatedly threatened to take legal action. Some nine years later P filed a copyright infringement suit. P sought relief only for acts of infringement occurring on or after January 6, 2006. D moved for summary judgment in part on the equitable doctrine of laches. The District Court granted the motion. The Ninth Circuit affirmed the laches-based dismissal. The Supreme Court granted certiorari.