## Facts

- Cathy Yvonne Stone claimed she was the biological daughter of songwriter Hank Williams, Sr., born five days after his death.
- Before Williams died, he and Stone’s mother executed a written agreement anticipating the child’s birth and arranging for the child to be raised and supported by Williams’s mother.
- After Williams’s mother died, Stone became a ward of the state and was later adopted; she was not told of her possible parentage or related legal proceedings until adulthood.
- Stone learned by about 1973 that there had been litigation concerning Williams’s estate and her possible relationship to Williams, but did not file a federal action until 1985.
- Defendants included Hank Williams, Jr. and multiple music publishers and related entities holding asserted interests in renewal copyrights through assignments and licensing arrangements.
- An Alabama Supreme Court decision in related probate litigation later recognized Stone as an heir and found intentional concealment of information about her identity and rights by certain actors connected to the earlier proceedings.
- After an earlier Second Circuit opinion affirming a complete laches bar was vacated on rehearing, the case returned to the district court, which recognized Stone as a “child” for federal renewal purposes but limited monetary relief based on laches; Stone appealed.

## Issues

1. Whether Stone qualified as a “child” of Hank Williams, Sr. for purposes of federal copyright renewal rights under the 1909 and 1976 Copyright Acts.
2. Whether laches barred Stone’s claims in whole or in part given her delay in filing suit and the prejudice asserted by defendants, including evidence loss and reliance-based transactions.
3. If Stone had renewal rights, what temporal scope of monetary relief and allocation of liability among assignees and publishers was proper.

## Decision

- The Second Circuit held Stone qualified as a “child” of Hank Williams, Sr. for federal copyright renewal purposes.
- The court held laches did not extinguish Stone’s renewal rights but limited her monetary recovery to renewal royalties attributable to the period beginning three years before the filing of the complaint.
- The court affirmed in part and reversed in part, refining the relief and responsibility among defendants for accounting and payment consistent with the limited recovery window and the renewal-term interests at issue.

## Legal Principles

- “Children” in the federal copyright renewal provisions is construed broadly to effectuate the renewal scheme’s protection of the author’s family; illegitimacy and adoption do not automatically defeat child status where state-law determinations support the familial relationship.
- Renewal rights vest by statute in designated beneficiaries at the time of renewal; pre-renewal assignments cannot eliminate a beneficiary’s statutory share of the renewal term.
- Laches may limit equitable relief when a plaintiff’s unreasonable and inexcusable delay causes prejudice, including loss of witnesses or evidence and defendants’ reliance-based changes in position through transactions.
- Equitable analysis of laches may account for concealment or misconduct that impeded timely assertion of rights, supporting partial rather than complete limitation of recovery.
- State probate and heirship determinations may be influential on factual and equitable questions (such as parentage and concealment), while the meaning of “child” under the Copyright Act remains a federal question.

## Conclusion

The Second Circuit recognized Stone as a statutory “child” entitled to a share of Hank Williams, Sr.’s copyright renewal interests, but applied laches to restrict monetary recovery to royalties attributable to the three years preceding suit and remitted allocation and accounting among the defendants accordingly.


Stone v. Williams, 970 F.2d 1043 (2d Cir. 1992)