Petrella v. Metro-Goldwyn-Mayer, Inc.

Boxer Jake LaMotta collaborated with friend Frank Peter Petrella (Frank) to write a book and two screenplays about LaMotta’s life. The works allegedly formed the basis for the 1980 movie Raging Bull. The works were registered with the United States Copyright Office in 1963. In a 1973 agreement, Frank and LaMotta assigned to Chartoff-Winkler Productions, Inc. (Chartoff) exclusive rights to the works with certain reservations for the authors. In September 1978, United Artists (UA), a subsidiary of Metro-Goldwyn-Mayer Studios, Inc. (MGM) (defendants), acquired the motion picture rights to Raging Bull in a written assignment from Chartoff. UA registered a copyright for the film in 1980. Frank died in 1981 during the original copyright term for the book and screenplays. Petrella’s renewal rights in the works passed to his heirs. In 1990, Petrella’s daughter, Paula (plaintiff), hired an attorney to advise Paula regarding her renewal rights, and the attorney filed a renewal application for the 1963 screenplay in 1991. In 1998, Paula’s attorney contacted UA, MGM, and several other companies, asserting that Paula had the rights to the 1963 screenplay and that any exploitation of a derivative work, including Raging Bull, infringed those rights. Paula sent letters to the companies over the next two years, accusing the companies of infringing her rights. The companies responded that they were not doing so, as the companies had all necessary rights in the script, and no substantial similarity of protectable elements between the screenplay and the film existed. Paula repeatedly threatened legal action until April 5, 2000, but did not sue the companies until 2009, alleging infringement. The district court granted summary judgment in the companies’ favor, holding that Paula’s claims were barred by the equitable defense of laches. Paula appealed.