Petrella v. Metro-Goldwyn-Mayer

The equitable defense of laches bars recovery of copyright claims where the plaintiff delays for 18 years, the reasons for delay are only inconveniences, and defendant expends considerable resources in the copyrighted work, even when the defendant receives profit during the plaintiff's delay.

Paula Petrella, daughter of boxer Jake LaMotta, filed suit against Metro-Goldwyn-Mayer, Inc. (“MGM”) in 2009 alleging various claims regarding the rights to the 1980 boxing film, Raging Bull. MGM obtained the rights to the movie in 1978, but Petrella renewed her rights in 1991 and notified MGM in 1998. The district court granted summary judgment for MGM, holding that the claim was barred by laches. The Ninth Circuit also held that Petrella’s copyright claim was barred by laches, because she consciously delayed her suit for 18 years, and the delay was unreasonable because her brother’s disability, mother’s fear of retribution, or her inability to afford a lawsuit were not supported by fact or sufficient to justify the delay. Further, the Court determined that MGM was prejudiced because it expended considerable amounts of resources to promote and market the film after Petrella gave notice in 1998. The Court rejected Petrella’s argument that MGM was not prejudiced because it made a profit during the delay. The Court denied Petrella’s unjust enrichment and accounting claims, because both are equitable remedies and barred by the equitable doctrine of laches. Finally, the Court denied MGM’s request for Rule 11 sanctions and attorney’s fees, because the district court did not abuse its discretion in denying MGM’s motions. AFFIRMED.