- Court: United States Supreme Court
- Area(s) of Law: Copyright
- Date Filed: February 24, 2022
- Case #: 20–915
- Judge(s)/Court Below: BREYER, J., delivered the opinion of the Court, in which ROBERTS, C. J., and SOTOMAYOR, KAGAN, KAVANAUGH, and BARRETT, JJ., joined. THOMAS, J., filed a dissenting opinion, in which ALITO, J. joined, and in which GORSUCH, J. joined, except as to Part II.
- Full Text Opinion
Petitioner, owner of copyrights for various fabric designs, filed a single application for registration of thirty-one separate designs. Respondent claimed that Petitioner’s copyright registration was invalid because Petitioner failed to publish all thirty-one works in a single publication, as required by the Copyright Office. Petitioner argued that it qualified for the safe harbor under 17 U.S.C. §411(b), because it did not have “knowledge that [the copyright application] was inaccurate.” The trial court agreed with Petitioner, but the Court of Appeals for the Ninth Circuit reversed because it concluded that the safe harbor “excused only good-faith mistakes of fact, not law.” On appeal, the Supreme Court of the United States held that the safe harbor provided by §411(b) excuses mistakes of law and mistakes of fact. The Supreme Court looked to related statutes in which the word “knowledge” applied to both law and facts. The legislative history indicated that Congress “enacted §411(b) to make it easier” for nonlawyers to register copyrights. Finally, cases decided before §411(b) was enacted held that inadvertent mistakes of law on registration certificates did not invalidate the copyrights. Without “an express statement to the contrary,” the Supreme Court will assume “that Congress intended to adopt the interpretation placed on that concept by the courts.” Davis v. Michigan Dept. of Treasury, 489 U.S. 803, 813 (1989). Therefore, Petitioner qualified for the safe harbor under §411(b). The judgment of the Ninth Circuit was VACATED.