Petrella v. Metro-Goldwyn-Mayer, Inc.
The Supreme Court ruled that a copyright owner who waited eighteen years to sue over the movie Raging Bull could still pursue her claim, because she only sought money for infringement that happened in the three years before she filed suit.
The decision means courts generally cannot use the old fairness doctrine of laches to throw out an entire copyright lawsuit as long as the plaintiff only seeks relief for recent infringement covered by the law's three-year deadline; delay can still affect what remedies a court awards, but not whether the case gets heard at all.
How it got here: A federal district court granted MGM summary judgment on laches grounds; the Ninth Circuit affirmed; Petrella asked the Supreme Court to review that ruling.
The Case in Depth
What happened
Frank Petrella and boxer Jake LaMotta wrote a screenplay about LaMotta's life, copyrighted in 1963. Petrella and LaMotta later sold the rights, which MGM eventually acquired and used to make the 1980 film Raging Bull. After Frank Petrella died, his daughter Paula Petrella inherited and renewed the copyright in 1991, then waited until 2009 to sue MGM for continuing to profit from the film, seeking damages only for the prior three years.
The question before the Court
If someone waits years to sue over a copyrighted work, can courts throw out her whole lawsuit just because of that delay, even though she only sought damages from the last three years?
The Court's answer
No — the Court ruled that laches (the equitable doctrine barring suits over unreasonable, harmful delay) cannot be used to throw out a copyright damages claim that was filed within the law's three-year time limit. Congress already built a delay safeguard into the Copyright Act by allowing recovery only for the three years before filing suit, so courts should not add a separate judge-made deadline on top of that.
The Court did leave room for delay to matter later: in truly extraordinary cases, a plaintiff's long wait can still limit the equitable remedies available, such as an injunction, once the case gets past the threshold stage. But that is a narrower, later-stage adjustment, not a total bar to bringing the lawsuit at all.
Curious how the Court got there? See the step-by-step legal reasoning →
Why it matters
Copyright owners, including authors' heirs who may not learn of or be able to afford challenging infringement right away, keep the ability to sue over ongoing exploitation of their work without being time-barred just because they waited. Companies that profit from creative works can no longer count on a long-delayed lawsuit being dismissed outright, though courts can still limit damages or injunctions based on the delay.
What changes now
The case returns to the lower courts, which must now decide the merits of Petrella's infringement claim without treating her delay as an automatic bar. If she wins, the district court may still weigh her delay in shaping any injunction or in calculating MGM's profits, but it cannot dismiss the suit outright based on laches. This is a final decision on the laches question, not a temporary order.
What this does not decide
The Court did not decide whether Petrella will actually win her infringement claim, nor whether MGM's specific use of Raging Bull infringes her copyright. It also left open how much, if any, a plaintiff's delay might narrow the remedies -- like profits or injunctions -- awarded if she does prevail.
Concurrences and dissents
Dissent — Justice Breyer
Justice Breyer argued that laches should remain available even for damages claims filed within the three-year window, because long delays can still cause real unfairness -- lost witnesses, lost evidence, and copyright owners strategically waiting to see if a work becomes profitable before suing. He pointed out that courts have long applied laches alongside other federal statutes of limitations and would have upheld the Ninth Circuit's dismissal of Petrella's suit on that basis.
How the Court got there
The legal reasoning, step by step
- The Court examined the Copyright Act's three-year statute of limitations, which lets a copyright owner recover only for infringing acts within three years before filing suit, and paired it with the 'separate-accrual rule,' under which each new infringing act starts its own three-year clock.
- Because Congress already built delay into the statute by capping recovery at three years back, the Court reasoned that the equitable defense of laches -- which lets a judge dismiss a suit because the plaintiff waited too long -- was largely unnecessary and should not be used to override that fixed legislative deadline.
- The Court distinguished laches from equitable tolling, explaining that tolling extends deadlines and interprets an existing statute of limitations, while laches historically filled gaps only where no such statute existed; since Congress supplied a statute of limitations here, laches had no comparable interpretive role.
- The Court rejected MGM's argument that allowing copyright owners to wait and see whether a work becomes profitable before suing was inherently unfair, noting the law does not require owners to sue over every possible infringement immediately and that delay-related evidence problems can hurt plaintiffs just as much as defendants.
- The Court concluded that laches cannot bar a damages claim brought within the statute's three-year window, though in truly extraordinary cases it may still narrow the equitable relief -- such as an injunction -- available at the remedy stage.
Doctrinal impact
Cases affected by this decision
Distinguishes Chirco v. Crosswinds Communities, Inc. (474 F. 3d 227)
The Court found no comparably extraordinary circumstances here to justify limiting equitable relief as that case did.
Reaffirms Stewart v. Abend (495 U. S. 207)
The Court relied on this case's rule that renewal rights revert to an author's heirs if the author dies before renewal.