Sturdza v. United Arab Emirates

281 F.3d 1287 (2002)

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Sturdza v. United Arab Emirates

United States Court of Appeals for the District of Columbia Circuit
281 F.3d 1287 (2002)

  • Written by Heather Whittemore, JD

Facts

Elena Sturdza (plaintiff) and Angelos Demetriou (defendant) were architects who competed for a contract to design an embassy building for the United Arab Emirates (defendant). After the United Arab Emirates agreed to award the contract to Sturdza, it entered into a contract with Demetriou. Sturdza filed a lawsuit in federal district court against the United Arab Emirates and Demetriou. With regard to Demetriou, Sturdza alleged that he had committed copyright infringement by stealing her embassy design and that he had committed several torts in violation of state law, including intentional interference with contractual relations, intentional infliction of emotional distress, and conspiracy to commit fraud. Demetriou filed a motion to dismiss Sturdza’s state-law tort claims, arguing that the claims were preempted by § 301 of the Copyright Act of 1976. That section provided that federal copyright law preempted state-law claims related to designs that fall under the subject matter of the Copyright Act and were equivalent to the exclusive rights provided by the act. Sturdza opposed the motion, arguing that her state-law claims contained extra elements not required for her copyright claim. Whereas the copyright claim required Sturdza to show that Demetriou had reproduced, performed, distributed, or displayed her copyrighted work, the state-law claims required Sturdza to show that Demetriou had engaged in other conduct, including intentional interference with her contractual rights, extreme conduct that caused her to experience severe emotional distress, and fraudulent behavior in furtherance of a conspiracy. The district court granted Demetriou’s motion and dismissed Sturdza’s state-law claims. Sturdza appealed.

Rule of Law

Issue

Holding and Reasoning (Tatel, J.)

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