Murray v. National Broadcasting Co., Inc.
United States Court of Appeals for the Second Circuit
844 F.2d 988 (1988)
- Written by Whitney Kamerzel , JD
Facts
Bill Cosby, a successful actor, spoke in an interview about creating a television comedy about a middle-class African American family. A television show of this type had never been made. Several years later, Hwesu Murray (plaintiff) pitched a proposal for a new show called “Father’s Day” to National Broadcasting Co., Inc. (NBC) (defendant). According to Murray, “Father’s Day” would feature Bill Cosby and focus on the positive family life of an African American family. Although NBC rejected Murray’s proposal, NBC aired The Cosby Show, starring Bill Cosby, which focused on the ordinary, positive family life of an African American family. The show was extremely successful. Murray sued NBC in federal court under state-law claims for breach of implied contract, misappropriation, conversion, and unjust enrichment. The district court dismissed Murray’s claims, holding that Murray’s idea was not novel and therefore was not property that could be given protection under state law.
Rule of Law
Issue
Holding and Reasoning (Altimari, J.)
Dissent (Pratt, J.)
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