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Bassett v. Mashantucket Pequot Tribe

United States Court of Appeals for the Second Circuit
204 F.3d 343 (2000)


Debra Bassett (plaintiff) ran a film-production studio, Bassett Productions. Bassett contracted with the Mashantucket Pequot Museum (the museum) (defendant) to develop a screenplay for a documentary describing the 1636–38 Pequot War. If the Mashantucket Pequot Tribe (the Tribe) (defendant) approved the screenplay, Basset Productions was to have the exclusive right to produce the documentary for display at the museum. After Bassett delivered the screenplay to the Tribe, the Tribe provided notice that it was terminating the contract. The Tribe proceeded to produce a documentary about the 1636–38 Pequot War on its own. Bassett sued the Tribe, alleging a mixture of copyright, contract, and tort claims. Bassett asserted that the Tribe infringed her copyright in the screenplay by using it without her consent and sought injunctive relief and other remedies. The Tribe filed a motion to dismiss the claims based on a lack of subject-matter jurisdiction. The district court agreed that the copyright claim was incidental to the state-law claims and therefore granted the motion to dismiss. Bassett appealed.

Rule of Law


Holding and Reasoning (Leval, J.)

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