Petrella v. Metro-Goldwyn-Mayer — Laches Cannot Bar a Timely Copyright Claim

Background

Paula Petrella is the daughter of Frank Petrella, who co-wrote a 1963 screenplay about boxer Jake LaMotta. Frank assigned his rights to MGM, which used the screenplay as the basis for the 1980 film Raging Bull. When copyrights can be renewed, the renewal right belongs to the author’s heirs — not the original assignee — under Supreme Court precedent. So in 1991, Paula Petrella recaptured her father’s share of the copyright in the renewed registration.

Paula notified MGM of her claim in 1998 but took no legal action for another nine years, filing suit in 2009 — within the Copyright Act’s three-year statute of limitations for damages. MGM moved for summary judgment on the ground of laches: the equitable doctrine that bars a plaintiff who delays unreasonably in bringing a claim, prejudicing the defendant. The lower courts agreed with MGM.

The Court’s Holding

Justice Ginsburg wrote for the majority: laches cannot be invoked to preclude adjudication of a claim for damages brought within the Copyright Act’s three-year statute of limitations. The Court applied the principle that when Congress has established a fixed limitations period, courts should not use laches to effectively shorten it — otherwise the legislature’s judgment about the appropriate time limit would be undermined.

The majority also noted the Copyright Act’s structure: each act of infringement triggers a fresh limitations period. So even a years-long delay in suing does not bar claims arising from infringing acts within the three years before filing. Laches might still apply in rare circumstances to limit equitable remedies (like injunctions), but it cannot extinguish a timely damages claim as a matter of law.

Key Takeaways

• Laches is not a valid defense to a copyright damages claim brought within the three-year statute of limitations.
• Each new act of infringement triggers a fresh three-year window for damages — copyright plaintiffs can wait and then sue for the most recent three years of infringement.
• Laches may still affect equitable remedies (injunctions) in extraordinary circumstances, but cannot categorically bar damages.
• Defendants facing ongoing infringement have no guarantee that delay by the rights holder creates a safe harbor — they may face a lawsuit at any time for recent acts.

Why It Matters

Petrella empowers rights holders — especially heirs who inherit copyrights — to bide their time and sue strategically. It also means companies that have been infringing for years without a lawsuit cannot assume they are in the clear simply because the rights holder has been silent. The decision reinforced that copyright’s three-year rolling limitations period is the primary time constraint, not equitable doctrines developed for different contexts.

The ruling was controversial because it allows plaintiffs to let infringement accumulate (and let defendants invest in infringing activities) before striking. Justice Breyer’s dissent argued this creates perverse incentives. Nonetheless, Petrella is settled law: file within three years of any infringing act, and laches will not save the infringer.