Court Holds That Laches Cannot Bar Delayed Copyright Claim

The Supreme Court subsequently granted certiorari to resolve a disagreement among the federal circuits on the application of the doctrine of laches to copyright infringement claims-like Petrella's-that are brought within the statutorily prescribed limitations period. During the oral argument on January 21, 2014, nearly all of the Justices questioned Petrella's assertion that the doctrine of laches should not apply to her action. However, the Court ultimately ruled for Petrella. Justice Ginsburg's majority opinion, joined by Justices Scalia, Thomas, Alito, Sotomayor, and Kagan, held that an equitable doctrine, such as laches, could not override a statutory limitations period despite Petrella waiting so long to bring suit. The Court observed that it has never applied laches to bar claims for "discrete wrongs occurring within a federally prescribed limitations period," and stated that doing so would defeat the uniformity achieved by the enactment of federal copyright legislation.1 Laches, Justice Ginsburg wrote, is appropriate for filling gaps in legislation, not for overriding it. The opinion emphasized that the limitations period on copyright claims itself accounts for the possibility of a delayed infringement claim: by imposing a limited "look-back" period, Congress restricted retrospective relief to the three years immediately prior to the time of suit, which, in this case, prevented Petrella from reaching the vast majority of the profits earned by MGM from Raging Bull since its initial release.2 The Court noted that there may be "extraordinary circumstances" in which the "consequences of a delay in commencing suit may be of sufficient magnitude to warrant, at the very outset of the litigation, curtailment of the relief equitably awardable," such as when injunctive relief would result in total destruction of the work.3 However, the Court did not find those circumstances present here.