In Petrella v. Metro-Goldwyn-Mayer, the US Supreme Court resolved a circuit split and ruled that the equitable defense of laches does not bar a plaintiff’s claim for damages brought within the Copyright Act’s three-year statute of limitations. The Court held that the owner of a screenplay could seek to recover damages from a movie studio for the film Raging Bull after waiting 18 years to file suit. In doing so, the Court all but eliminated the laches defense in copyright infringement actions and established a precedent that allows copyright owners to seek damages even if they waited many years to bring suit and the defendant invested significant resources in reliance on that delay.
Frank Petrella, in collaboration with boxing champion Jake LaMotta, wrote a screenplay that chronicled the boxer’s career. In 1976, Petrella and LaMotta assigned their motion picture rights in the screenplay, which MGM acquired. MGM released Raging Bull in 1980.
Rights in the copyright to the screenplay reverted to Petrella’s daughter, Paula Petrella, who renewed the copyright and became its sole owner in 1991. Ms. Petrella’s attorney notified MGM that she had obtained the copyright in the screenplay and that MGM’s continued exploitation of Raging Bull infringed her rights. She did not file suit against MGM until 2009, however, some 18 years after acquiring ownership of the work.
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