Maljack Productions v. Motion Picture Association of America
United States Court of Appeals for the District of Columbia Circuit
52 F.3d 373 (1995)
- Written by Eric Miller, JD
Facts
Maljack Productions, Inc. (Maljack) (plaintiff) produced a low-budget film called Henry: Portrait of a Serial Killer. Maljack was not a member of the Motion Picture Association of America (MPAA) (defendant) but still submitted the film to the MPAA’s ratings board, the Code and Rating Administration (CARA), for a fee. CARA gave the film an X—the most restrictive rating—on the basis of excessive violence and other extreme content. Maljack brought suit, alleging that CARA gave the film an X rating because Maljack was not a member of the MPAA and that CARA gave films with equal or greater violence a more marketable R rating. Maljack’s claim was based on the implied covenant of good faith and fair dealing, which Maljack alleged the MPAA breached by discriminatorily applying its ratings standards. The district court dismissed the complaint for failure to state a claim. Maljack moved for leave to amend the original complaint, which the district court denied. Maljack appealed. The United States Court of Appeals for the District of Columbia Circuit granted certiorari.
Rule of Law
Issue
Holding and Reasoning (Williams, J.)
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