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Warner Chappell Music, Inc. v. Nealy

601 U.S. 366, 144 S. Ct. 1135 (2024)

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Warner Chappell Music, Inc. v. Nealy

United States Supreme Court
601 U.S. 366, 144 S. Ct. 1135 (2024)

SC

Facts

Sherman Nealy (plaintiff) and Tony Butler released an album and several other songs under the name Music Specialist, Inc. (MSI). Soon after, Nealy went to jail on drug charges. Nealy got out of jail in 2015. While Nealy was in jail, unbeknownst to him, Butler executed a licensing deal with Warner Chappell Music, Inc. (Warner) (defendant), permitting Warner to use the MSI works. In 2018, Nealy sued Warner for copyright infringement. Nealy claimed that the infringing activities began in 2008. Nealy relied on the discovery rule, which stated that the Copyright Act’s statute of limitations did not begin to run until the copyright owner discovered the infringing use. Nealy stated that because he was in jail, he was not aware of the infringing acts until after he got out, in 2016. Warner argued that even though Nealy could bring suit under the discovery rule for infringing acts that occurred more than three years prior, he could not recover damages for such acts. The district court agreed with Warner. The United States Court of Appeals for the Eleventh Circuit reversed. The United States Supreme Court granted certiorari.

Rule of Law

Issue

Holding and Reasoning (Kagan, J.)

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