Broadcast Music, Inc. v. Roger Miller Music, Inc.

Roger Miller (Miller), a successful country-music artist, obtained copyrights on many of his songs. Miller died in 1992 and was survived by his wife Mary Arnold Miller (Mary), his daughter Shannon Miller Turner (Turner) (defendant), and his six other children. After Miller’s death, his surviving family members renewed the copyrights and—pursuant to § 304(a) of the Copyright Act of 1976, which provided that renewal copyright interests of a deceased artist are shared between the artist’s surviving spouse and children—the renewal copyright interests vested in Mary and the seven children. Mary and six of the children conveyed their interests to Roger Miller Music, Incorporated (RMMI) (defendant). Broadcast Music Incorporated (BMI) (plaintiff) licensed songs written by Miller and therefore owed royalties. However, BMI did not know how the royalties were to be divided proportionally between Turner and RMMI. Therefore, BMI filed an interpleader action seeking a determination from the district court. The district court found that, when a copyright is renewed after the author’s death, the surviving spouse and children each individually receive an equal share of the renewal copyright interests. RMMI appealed and moved for summary judgment, arguing that § 304(a) should be interpreted to provide disproportionate shares between the surviving spouse and children in that the surviving spouse should obtain a 50-percent share while the children split equally the remaining 50-percent share.