Globe Newspaper Co. v. Walker

Background

A partnership that owned a copyrighted map of Massachusetts’ electric railways sued a newspaper company in federal court, saying the paper printed and sold copies without permission. The newspaper argued there is no civil action under the copyright law to recover money damages for maps. The trial court sustained that view at first, but a federal appeals court reversed, a jury later awarded $250 to the map owner, and the newspaper renewed its objections to federal jurisdiction. The question was certified to the Supreme Court about whether the federal court properly had power to hear a damages claim over a map copyright.

Reasoning

The Court examined the federal copyright statutes and related decisions and asked whether Congress intended map owners to have ordinary money-damage lawsuits in federal court. The statutes create the copyright and set out specific remedies for different works. For books the law expressly allows a damages action, but for maps Congress provided forfeiture of plates and copies, penalties, and the ability to seek injunctions. The Court applied the general rule that when Congress prescribes a special remedy for a statutory right, that remedy must be used. Because Congress had set out particular remedies for maps and did not provide a general damages action, the Court held the federal court lacked jurisdiction to hear the money-damages claim and reversed the lower court’s decision.

Real world impact

Map owners cannot rely on ordinary federal damages suits and are limited to the remedies the copyright statute provides, such as forfeiture, penalties, or injunctions. Affected parties who want broader relief must seek statutory change from Congress; the ruling ends this federal damages avenue for map-infringement claims.