Raymond G. Schreiber Revocable Trust v. Estate of Knievel

When there was no "clear, signed, written transfer of ownership," there was no transfer of copyrights.

Opinion (George): Robert "Evil" Knievel ("Knievel") was a daredevil who owned the copyrights to several stunt performances, pieces of artwork, and his autobiography. This case arises from a contract dispute between Knievel and Raymond Gary Schreiber ("Schreiber"). In 1982, Knievel and Schreiber executed a "bill of sale" which purportedly assigned a number of Knievel's copyrights to Schreiber. Schreiber brought suit after Knievel's death seeking a declaratory ruling as to each party's rights under the contract as well as advancing theories of breach of good faith, breach of contract, and fraud. The court addressed issues relating to copyright for only the rolls of stunt footage mentioned in the bill of sale. To transfer a copyright, there must be a "clear, signed, written transfer of ownership." There was no evidence that Knievel filed for federal copyright protection for the rolls of stunt footage mentioned in the bill of sale. The court therefore reasoned that bill of sale could not "clearly reflect an assignment or transfer of any copyrighted material." The court further noted that the bill of sale did not specify which rolls of tape were being transferred. The court therefore concluded that Schreiber could not maintain his claim to copyright ownership of the stunt footage, and accordingly declared Schreiber's claim of copyright INVALID.