Supreme Court Rules Copyright Damages May Extend Beyond Statute of Limitations

The Supreme Court of the United States has ruled that copyright damages may extend beyond the statute of limitations. In the case of Warner Chappell Music, Inc. v. Nealy, the court upheld the decision of the Eleventh Circuit Court of Appeals. Within this article, our Boca Raton copyright law attorney provides an overview of the decision from the nation’s highest court.

Case Analysis: Warner Chappell Music, Inc. v. Nealy 

Facts

 The underlying dispute in this case involved a decades-old (short-lived) music venture launched by Sherman Nealy and Tony Butler. The now-defunct company was called Music Specialist, Inc. The corporation was based in Florida. Eventually, in the late 1980’s, Mr. Nealy was arrested and incarcerated on drug charges. During that time, Mr. Butler formed a new business entity and began licensing music. A complex copyright dispute arose involving many different parties, including Warner Chappell Music, Inc. In 2018, Mr. Nealy filed a copyright infringement lawsuit against Warner Chappell and other entities for copyright infringement dating back to 2008.

Legal Issue

 While the copyright infringement case before the Supreme Court has an extremely complex legal and procedural history, the central legal issue is relatively straightforward:

• Can the plaintiff in a copyright infringement claim recover damages for an act that occurred more than three years before they filed their lawsuit?

Notably, the United States Copyright Act imposes a three year statute of limitations for copyright infringement claims. That statute begins running on the last date the action accrued.

 Decision

 In a 6 to 3 decision that split the Court’s Conservative majority, Justice Elena Kagan wrote that the U.S. Copyright Act allows a copyright holder to seek damages for any timely infringement claim—regardless of whether or not the infringement in question occurred more than three years before the lawsuit was filed. In other words, the three year statute of limitations for copyright infringement litigation does not stop a plaintiff from seeking damages for infringement that occurred more than three years before the lawsuit was brought. Notably, the “Discovery rule” was a big issue in this case. The plaintiff “discovered” the copyright infringement nearly a decade after the actual infringing act. However, under U.S. copyright law, the claim does not accrue for the purposes of the statute of limitations until the infringement was or reasonably should have been discovered. The court found that there is no separate statute of limitations for copyright infringement damages.

 Get Help From a Copyright Infringement Attorney in South Florida Today

At Perkins Law, our Florida copyright infringement lawyer is standing by, ready to help you navigate a complex IP law matter. If you have any questions or concerns about the statute of limitations in copyright infringement cases, please do not hesitate to contact us today to set up your strictly confidential, no commitment initial appointment with a top attorney. From our legal office in Boca Raton, we are well-situated to handle copyright disputes across the whole region.

Source:

supremecourt.gov/opinions/23pdf/22-1078_4gci.pdf