## Facts

- Shirley Goodman and Leonard Lee performed and composed music together from 1953 to 1961 as the duo “Shirley and Lee.”
- In 1956, they created the song “Let the Good Times Roll,” which later generated substantial royalties through rerecordings and other exploitation.
- The song was registered for copyright listing Leonard Lee as the sole author, and he received all royalties during his life (1956–1976).
- After Leonard Lee’s death in 1976, his widow and daughter (Audrey and Nikki Lee) inherited and continued collecting royalty income from the song.
- In 1984, the Lees authorized renewal of the copyright under 17 U.S.C. § 304(a); Goodman asserted she then first learned she was not listed as an author and demanded her share.
- Goodman sued in federal court seeking a declaration of co-authorship/joint ownership, amendment of the copyright registration, and an accounting for royalties; she also asserted a state-law fraud claim against Audrey Lee.
- A jury found Goodman was a co-author and did not discover her omission until 1984; the district court declared her a joint owner, ordered the Register of Copyrights to list her as co-author/joint owner, and awarded one-half of royalties received by the Lees from 1976 to 1993 plus prejudgment interest at Louisiana Civil Code rates.

## Issues

1. Whether sufficient evidence supported the jury’s finding that Goodman was a joint author and thus joint owner of the copyright in “Let the Good Times Roll.”
2. Whether federal jurisdiction properly existed over the declaratory claim of co-authorship under the Copyright Act, and how to characterize the claim for an accounting between co-owners.
3. Whether the accounting claim was barred by limitations or laches, and whether recovery could extend back to royalties received beginning in 1976.
4. Whether prejudgment interest was properly awarded on past royalties, including the accrual date and the use of Louisiana Civil Code interest rates.

## Decision

- The Fifth Circuit affirmed the judgment.
- The court held the evidence was sufficient to support the jury’s finding of joint authorship and joint ownership.
- The court reaffirmed exclusive federal jurisdiction over the declaratory co-authorship claim because it required applying and interpreting the Copyright Act.
- The court treated the accounting for royalties as a claim between co-owners governed by Louisiana law, not as a federal copyright infringement claim.
- The court upheld an accounting awarding Goodman one-half of royalties received by the Lees from 1976 to 1993.
- The court upheld prejudgment interest calculated under Louisiana Civil Code rates, accruing as royalties were received.

## Legal Principles

- A declaratory claim to establish co-authorship and ownership under the Copyright Act arises under federal law and falls within exclusive federal jurisdiction.
- Disputes between copyright co-owners over profits are properly addressed through an accounting between co-owners rather than an infringement claim by one co-owner against another.
- For an accounting between co-owners, state law may govern the obligation to share revenues and the applicable prescriptive periods, including accrual principles tied to discovery and receipt of revenues.
- Under Louisiana law applied by the court, a co-owner’s duty to account arises when revenues (royalties) are received, supporting prejudgment interest from the time of receipt at Louisiana Civil Code rates.

## Conclusion

The Fifth Circuit upheld a judgment recognizing Goodman as a joint author and joint owner of “Let the Good Times Roll,” requiring correction of the copyright records and awarding her one-half of royalties collected by the heirs from 1976 to 1993 with prejudgment interest accruing when each royalty payment was received under Louisiana law.


Goodman v. Lee, 78 F.3d 1007 (5th Cir. 1996), cert. denied, 519 U.S. 861 (1996)