Facts

Nelson-Salabes, Incorporated (Nelson) (plaintiff) was hired to design a proposed assisted-living facility in Baltimore County called Satyr Hill. Nelson’s architectural drawings were submitted, as required by the county, with the development plans. The plan was approved. Nelson’s design for the Satyr Hill site included a three-story, Y-shaped building and several distinctive features on the front, including an octagonal silo at the entrance, bay windows, and vertical protrusions with gable roofs midway down each side of the building to create visual interest. The process of obtaining approval was long, and Satyr Hill’s site approval was therefore a significant benefit to Morningside Holdings (Morningside) (defendant) when it purchased the site from the initial developers. After purchasing the site, Morningside told Nelson it would not continue as architects on the project. Nelson informed Morningside that the existing architectural drawings could not be used for the site if a new architectural firm was retained. However, to avoid having to obtain an entirely new approval for the plans, Morningside directed the new architects to make only minor revisions and changes to the structure and outer appearance. Like the Nelson plans, the new plans featured a Y-shaped building, an octagonal silo at the entrance, brick siding on the first floor, and vertical protrusions with gable roofs. Nelson brought a claim against Morningside for copyright infringement.

Rule of Law

Issue

Holding and Reasoning (Black, J.)