May 19, 2014 United States Supreme Court opinion

Patrella v Metro Goldwyn Meyers, Inc.

Patrella sued for copyright infringement. Metro moved for judgment based on laches and the district court granted judgment on that basis. The 9th Circuit affirmed. Resolving a circuit split, the Court, 6-3, reversed. The majority held that the three limitation period in 17 USC 507 controlled when a suit can be brought under the copyright Act and thus laches has no place in barring suits when Congress has allowed them to be brought. The majority noted that laches is a gap filler and here there is no gap to fill, the fact that equitable tolling is read into federal statutes of limitations does not mean laches must be read there as well, that copyright owners do not need to sue about every possible infringement to prevent the loss of future claims, that the possible loss of evidence was before Congress when it enacted 507 and cannot provide a basis for allowing laches to prevent timely claims and lies about why a claim was delayed can be disposed of under estoppel principles. The majority finally pointed out that there are equitable grounds to limit remedies here or otherwise make any judgment reasonable under the circumstances taking into account the behavior of both parties since Patrella notified Metro of her interest in the film Ragin Bull. The dissent argued that laches should be available for extraordinary cases where a copyright holder has sat on its rights waiting for an infringing use to become profitable and then suing as that behavior is inequitable. The dissent also argued that the legislative history of 507 and the modern rules of civil practice support allowing the invocation of laches in appropriate circumstances such as this case where Patrella waited 18 years after notification of her rights to actually sue for infringement.

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