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Richlin v. Metro-Goldwyn-Mayer Pictures, Inc.

531 F.3d 962(2008), cert. denied, 129 S. Ct. 1002 (2009)

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Richlin v. Metro-Goldwyn-Mayer Pictures, Inc.

United States Court of Appeals for the Ninth Circuit

531 F.3d 962(2008), cert. denied, 129 S. Ct. 1002 (2009)

Facts

Richlin and Edwards coauthored a fourteen-page treatment that served as the basis for the movie The Pink Panther and numerous derivative works. Shortly after writing the treatment, the Mirisch Corporation of Delaware engaged Richlin and Edwards on a work-made-for-hire basis to develop the treatment into a script for the movie. Richlin and Edwards then assigned all rights in the treatment and script to Mirisch. The movie was released in 1963 and registered with the US Copyright Office with Mirisch listed as the author. The later-issued renewal certificate identified Metro-Goldwyn-Mayer Pictures, Inc. (MGM) (defendant) as the claimant and Mirisch as the author. Neither the treatment nor the script was ever registered. After Richlin’s death, his heirs filed suit claiming that, because Richlin coauthored the treatment that was incorporated into the movie, Richlin was also a coauthor of the movie and therefore held an interest therein. The district court held in favor of MGM after concluding that Richlin was not a coauthor of the movie. The Richlin heirs appealed.

Rule of Law

Issue

Holding and Reasoning (Wardlaw, J.)

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