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Capitol Records, Inc. v. Thomas-Rasset

692 F.3d 899 (2012)

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Capitol Records, Inc. v. Thomas-Rasset

United States Court of Appeals for the Eighth Circuit

692 F.3d 899 (2012)

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Facts

Jammie Thomas-Rasset (defendant) downloaded and distributed 24 copyrighted songs using file-sharing platforms. Capitol Records, Inc., and other companies holding the songs’ copyrights (plaintiffs) sued for injunctive relief and statutory damages under the Copyright Act. The first jury awarded the companies $222,000, but the trial court ordered a new trial due to a faulty jury instruction. The second jury awarded $1,920,000, but the court remitted it to $54,000, and the companies opted for a new trial instead of accepting remittitur. The third jury awarded $1,500,000, but the court ruled that the maximum amount constitutional due process allowed was $54,000, and again reduced the award to $54,000. The companies appealed, seeking only the $222,000 awarded in the first trial as a tactical strategy and an injunction against making copyrighted works available to the public. Thomas-Rasset cross-appealed, arguing that any award of statutory damages was unconstitutional.

Rule of Law

Issue

Holding and Reasoning (Colloton, J.)

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