The United States Supreme Court recently brought final resolution to Mandeville-Anthony v. Walt Disney Co., a dispute over the ownership of Disney and Pixar’s animated movies “Cars” and “Cars 2,” and the spin-off television series “Cars Toon.” The plaintiff originally filed the case in 2011 in the Central District of California alleging two claims. First, Mandeville-Anthony claimed that the movies infringed his copyrights in his works “Cookie & Co.” and “Cars/Auto-Excess/Cars Chaos,” which, like Disney/Pixar’s Cars franchise, featured anthropomorphic cars without human characters. Plaintiff specifically alleged that Disney’s “Mater” character, below left, infringed his “Manny Morris” character, below right.
Second, the plaintiff sued for breach of implied contract based on his claim that that Disney stole the idea from works that he had submitted to Disney and Pixar employees. Mandeville-Anthony alleged that he had mailed his works, unsolicited, to various production companies and movie studios, including Walt Disney, and also that he had met and personally delivered his proposals to Jim Morris, then an executive at Lucasfilm, who later joined Pixar.
In a brief, one-page decision, the district court granted the defendants’ motion for judgment on the pleadings. The court dismissed the copyright infringement claim because it found that the works were not substantially similar as a matter of law. The court also dismissed the breach of implied contract claim, holding that the two-year statute of limitations began running on the date the defendants first began to use the plaintiff’s idea without compensation, and therefore had expired.
On appeal, the Ninth Circuit affirmed without oral argument. In an unpublished opinion, the Ninth Circuit held that there “was no substantial similarity between the works as a matter of law, and any similarity in the general concepts of car racing and anthropomorphic cars is unprotected.” It also affirmed the district court’s ruling that the breach of implied contract claim was barred by the statute of limitations, holding that no exceptions were applicable.
On April 29, the Supreme Court denied Mandeville-Anthony’s petition for certiorari in the case without comment, marking the end of the road for Mandeville-Anthony’s claims.