Petrella v. Metro-Goldwyn-Mayer, Inc.
SUPREME COURT CASES RELATED BY THIS ISSUE
Whether the nonstatutory defense of laches is available without restriction to bar all remedies for civil copyright claims filed within the three-year statute of limitations prescribed by Congress.
In its brief, The U.S. Chamber urged the Supreme Court to affirm the Ninth Circuit’s judgment holding that the defense of laches may, in appropriate circumstances, bar claims for copyright infringement brought within the statute of limitations. Nothing about the text or structure of the statute of limitations governing federal claims for copyright infringement indicates that Congress intended to abrogate federal courts’ power to apply laches to stale claims for copyright infringement that would prejudice defendants. Applying laches to such claims would be consistent with Supreme Court precedent holding that laches may bar other federal statutory claims, such as claims for employment discrimination, antitrust violations, and certain ERISA claims, brought within the applicable limitations period. It would also be consistent with decisions from federal courts of appeals and state courts, and with prominent treatises, similarly holding or recognizing that a party may raise a laches defense within the period of an applicable statute of limitations.
In addition, there is no merit to petitioner’s argument that laches cannot bar claims for legal relief (such as copyright infringement) because it is an equitable doctrine. Rather, after law and equity merged in federal court in 1938, federal courts retain the authority to apply equitable doctrines in cases raising legal claims. Indeed, petitioner’s argument cannot be reconciled with numerous Supreme Court cases applying equitable doctrines such as abstention and forum non conveniens in cases raising legal claims; there is no principled basis for applying those equitable doctrines to legal claims, but refusing to apply the equitable doctrine of laches to them as well.
This case has not been decided yet.