Reed Elsevier, Inc. v. Muchnick
United States Supreme Court
559 U.S. 154 (2010)
In New York Times Co. v. Tasini, 533 U.S. 483 (2001), the United States Supreme Court upheld a finding of copyright infringement related to the publication in online databases and print media of works by freelance authors. Several copyright-infringement cases hinging on the outcome of the decision in Tasini had been stayed pending a holding. After Tasini was decided, the stayed lawsuits were consolidated for hearing in the United States District Court for the Southern District of New York. The district court certified a class of freelance authors with at least one allegedly infringed copyright. The court then approved a class settlement. Irvin Muchnick (plaintiff) and nine other freelance authors objected to the district court’s certifications, but the district court overruled the objections and entered final judgment. Muchnick and the other nine plaintiffs appealed. Although many of the class members had registered their copyrights with the Register of Copyrights prior to initiating an infringement action, some had not. On appeal, the circuit court ordered briefing on the question of whether the requirement under § 411(a) of the Copyright Act that copyrights be registered was jurisdictional in nature. The court of appeals held that the district court had lacked jurisdiction to certify both the class and the settlement. The plaintiffs and the defendants both petitioned for a writ of certiorari, which was granted by the United States Supreme Court.
Rule of Law
Holding and Reasoning (Thomas, J.)
What to do next…
Unlock this case brief with a free (no-commitment) trial membership of Quimbee.
You’ll be in good company: Quimbee is one of the most widely used and trusted sites for law students, serving more than 97,000 law students since 2011. Some law schools—such as Yale, Vanderbilt, Berkeley, and the University of Illinois—even subscribe directly to Quimbee for all their law students. Read our student testimonials.
Learn more about Quimbee’s unique (and proven) approach to achieving great grades at law school.
Quimbee is a company hell-bent on one thing: helping you get an “A” in every course you take in law school, so you can graduate at the top of your class and get a high-paying law job. We’re not just a study aid for law students; we’re the study aid for law students. Read more about Quimbee.
Here's why 174,000 law students have relied on our case briefs:
- Written by law professors and practitioners, not other law students. 14,000 briefs, keyed to 188 casebooks. Top-notch customer support.
- The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
- Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
- Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.