Petrella v. MGM, Inc. (2013)
- Docket
- 12-1315
- Decided
- 2013-01-01
Summary
Question: Does the doctrine of laches apply without restriction to civil copyright claims that are within the bounds of the federal three-year statute of limitations on such cases? Conclusion: No. Justice Ruth Bader Ginsburg delivered the opinion of the 6-3 majority. The Court held that the doctrine of laches could not be used to bar a copyright suit that seeks relief for damages that occurred within the three-year timeframe allowed by the Copyright Act. This limitation prevents a defendant from being held liable for multiple violations of the same work. Because Petrella did not seek relief for damages prior to three years before the filing of her suit, the doctrine of laches does not apply to this case. The Court also held that the doctrine of laches has never been used to bar claims for wrongs that occurred within the acceptable timeframe, so there was no precedent for the type of reading that MGM argued was necessary. Because laches originally served as a guide to adjudicating copyright disputes when there was no statutory limitation, there is no reason to use the doctrine to interpret the statute. Justice Stephen G. Breyer wrote a dissent in which he argued that the doctrine of laches must be applied to the three-year statute of limitations in order for the courts to protect the equity of the legal system. Allowing the three-year limitation to control every copyright case regardless of the circumstances could create loopholes such as permitting plaintiffs to sue for copyright violations on the same work every three years or to wait long enough that evidence that could be used to defend against the suit is lost. Justice Breyer also argued that judicial precedent held that statutory limitations are subject to further adjustment in the name of equity. Chief Justice John G. Roberts, Jr. and Justice Anthony M. Kennedy joined in the dissent.