## Facts

- Jake LaMotta and Frank Petrella collaborated on works about LaMotta’s life, including a 1963 screenplay.
- In 1976, LaMotta and Frank Petrella assigned copyrights (including renewal rights) to Chartoff‑Winkler Productions, later transferred to United Artists, a subsidiary of MGM.
- United Artists released and registered the film *Raging Bull* in 1980; MGM continued to exploit the film.
- Frank Petrella died in 1981; under the renewal regime, renewal rights reverted to his heirs.
- In 1991, Paula Petrella renewed the copyright in the 1963 screenplay.
- In 1998, Petrella’s counsel notified MGM that continued exploitation of *Raging Bull* infringed her rights; she did not sue until 2009.
- Petrella’s complaint sought damages and injunctive relief limited to alleged infringements occurring within three years before suit (on or after January 5, 2006), consistent with 17 U.S.C. § 507(b).

## Issues

1. Whether laches may bar a copyright infringement claim for damages that is timely under the three-year limitations period in 17 U.S.C. § 507(b).
2. Whether, and to what extent, delay may affect the availability or scope of equitable relief in a timely copyright action.

## Decision

- The Supreme Court reversed the Ninth Circuit and remanded.
- Laches cannot bar claims for legal damages brought within § 507(b)’s three-year window.
- The Court reaffirmed the separate-accrual rule: each infringing act triggers a new three-year limitations period, but recovery is limited to infringements occurring within three years of filing.
- Although laches cannot defeat timely damages claims, delay may be considered when shaping equitable relief, and equitable estoppel remains available where the plaintiff’s conduct misled the defendant.

## Legal Principles

- When Congress supplies a statute of limitations, courts may not use laches to override the legislatively chosen timeliness rule for legal relief.
- Under the separate-accrual rule in copyright, successive infringements are discrete wrongs; each act is actionable only if sued upon within three years of that act.
- A plaintiff’s delay may justify limiting or denying equitable remedies (such as injunctions) even when damages claims are timely.
- Equitable estoppel, distinct from laches, may bar relief where the plaintiff’s misleading conduct induced detrimental reliance by the defendant.

## Conclusion

The Court held that laches cannot preclude adjudication of a timely copyright claim for damages under § 507(b), while recognizing that delay can still influence equitable remedies and that equitable estoppel may apply in cases involving misleading conduct and reliance.


Petrella v. Metro-Goldwyn-Mayer, Inc., 572 U.S. 663 (2014)