PETRELLA v. MGM, INC.
After Jake LaMotta retired from boxing, he and Frank Peter Petrella (F. Petrella) created two screenplays and a book based on LaMotta's life. These works were registered with the United States Copyright Office in 1963, 1973, and 1970, respectively. In 1976, LaMotta and F. Petrella signed a written agreement that granted the exclusive rights to the book and the screenplays to Chartoff-Winkler Productions, Inc, which in turn assigned those rights to a subsidiary of Metro-Goldwyn-Mayer Studios, Inc. (MGM), United Artists Corporation. In 1980, United Artists Corporation registered a copyright for the film "Raging Bull" based on LaMotta and F. Petrella’s work. When F. Petrella died in 1981, which was still within the original 28-year period of the copyright, his renewal rights passed to his heirs.
In 1991, Paula Petrella (Petrella), the daughter of F. Petrella, filed an application for the renewal of copyright rights on the 1963 screenplay. In 1998, Petrella’s attorney contacted MGM and asserted that Petrella had obtained the rights to the screenplay and its derivative works, which included the movie "Raging Bull," and that MGM was infringing on those rights. MGM argued that the 1963 screenplay was a collaboration between LaMotta and F. Petrella, so MGM retained the rights to the screenplay under the agreement with LaMotta. MGM also argued that there was no “substantial similarity of protectable elements” between the 1963 screenplay and the film. In 2009, Petrella sued MGM for copyright infringement, and the federal district court granted summary judgment for MGM under the doctrine of laches, which prevents a legal claim from being enforced if a long delay in filing the claim adversely affected the defendant’s ability to fight the claim. The U.S. Court of Appeals for the Ninth Circuit affirmed.
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?