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Goodman v. Lee

78 F.3d 1007 (1996)

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Goodman v. Lee

United States Court of Appeals for the Fifth Circuit

78 F.3d 1007 (1996)

Facts

Shirley Goodman (plaintiff) was a singer-songwriter. Goodman performed in a duo with her childhood friend and later husband, Leonard Lee, under the name Leonard and Shirley. In 1956, the duo wrote the song “Let the Good Times Roll,” which was covered by notable artists and largely a commercial success. On the initial copyright, Leonard Lee was listed as the sole author and owner and consequently received all the royalty payments from 1956 until his death in 1976. After his death, Leonard Lee’s daughters, Audrey and Nikki Lee (defendants), received the royalty payments. In 1984, Audrey and Nikki authorized a renewal to the copyright. Goodman demanded her share of royalties for the song but was rebuked. Thus, in 1985, Goodman filed suit in federal court seeking a declaration that she was the co-owner of “Let the Good Times Roll,” and that she was entitled to half of the royalties received from the song. After a full trial, a jury returned a verdict in favor of Goodman, finding that she was a co-owner of the song and that she did not discover that she was not on the copyright until 1984. The district court then entered a final judgment, awarding Goodman half of the royalties paid after Lee’s 1976 death, plus prejudgment interest. Audrey and Nikki Lee appealed, arguing that Goodman’s claim for an accounting was subject to the Copyright Act’s three-year statute of limitations and thus was barred.

Rule of Law

Issue

Holding and Reasoning (Wiener, J.)

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