Petrella v. Metro-Goldwyn-Mayer, Inc.

Background

A daughter of a deceased screenwriter renewed her father’s 1963 screenplay copyright and later sued a movie studio that makes and markets the film based on that screenplay. She filed suit in 2009 and sought money and an injunction only for infringements occurring within three years before her filing (on or after January 6, 2006). The studio argued the case should be dismissed because she waited many years to sue, invoking the equitable defense called laches (unreasonable, prejudicial delay).

Reasoning

The Court focused on the Copyright Act’s three-year limit for bringing suit and the rule that each new act of copying starts a fresh three-year clock. The Justices said that when a copyright owner brings a claim for money damages within that statutory three-year period, courts cannot use laches to bar those legal claims. The Court explained that delay can still matter: in rare and exceptional circumstances laches can block particular equitable relief at the outset, and a plaintiff’s delay may be considered later when deciding injunctions or how much of the infringer’s recent profits must be returned (§504(b)). The Court reversed the lower court’s dismissal and sent the case back for further proceedings.

Real world impact

The decision lets copyright owners pursue monetary recovery for recent infringements even after long earlier delays, but it preserves judges’ power to limit or shape equitable remedies in extraordinary cases. Defendants can still offset expenses and profits attributable to noncopyright factors, and estoppel remains available if a copyright owner misled the defendant.

Dissents or concurrances

A dissenting Justice argued laches should sometimes bar damages when long delay causes severe unfairness to a defendant, noting real examples where evidence or witnesses were lost over decades.