Ehat v. Tanner
United States Court of Appeals for the Tenth Circuit
780 F.2d 876 (1985)
- Written by Sarah Holley, JD
Facts
During the course of his research on the background of the Church of Jesus Christ of Latter-Day Saints (the LDS Church), Andrew Ehat (plaintiff) collected notes from a series of journals at the LDS Church archives. Ehat provided a colleague material consisting of quotes he had taken from the journals as well as his own notes and comments. This material was taken from the colleague’s office, copied, and replaced. One of these unauthorized copies reached the hands of Gerald and Sandra Tanner (defendants). The Tanners, who were in the business of publishing and distributing works relevant to the LDS Church, blacked out the notes and comments contributed from Ehat and sold the resulting copies to the public. Ehat thereafter filed suit against the Tanners, asserting claims under the Copyright Act as well as state common-law claims for unfair competition and unjust enrichment. The district court granted summary judgment for the Tanners as to Ehat’s claims under the Copyright Act but entered judgment for Ehat as to his state-law claims. The Tanners appealed, arguing that Ehat’s state-law claims were preempted by the Copyright Act.
Rule of Law
Issue
Holding and Reasoning (Seymour, J.)
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