Warner Chappell Music, Inc. v. Nealy

Judge: Elena Kagan
Opinion Date: May 9, 2024

The case revolves around a dispute between Sherman Nealy and Warner Chappell Music, Inc. Nealy, who co-founded Music Specialist, Inc. in 1983, alleged that he held the copyrights to the company’s songs and that Warner Chappell’s licensing activities infringed his rights. The infringing activity, according to Nealy, dated back to 2008, ten years before he brought suit. Nealy sought damages and profits for the alleged misconduct, as authorized by the Copyright Act. To proceed with his claims, Nealy had to show they were timely under the Copyright Act, which requires a plaintiff to file suit “within three years after the claim accrued.” Nealy argued that all his claims were timely under the discovery rule because he did not learn of Warner Chappell’s infringing conduct until 2016, less than three years before he sued.

In the District Court, Warner Chappell accepted that the discovery rule governed the timeliness of Nealy’s claims. However, it argued that even if Nealy could sue under that rule for infringements going back ten years, he could recover damages or profits for only those occurring in the last three. The District Court agreed, and Nealy appealed. The Eleventh Circuit reversed the decision, rejecting the notion of a three-year damages bar on a timely claim.

The Supreme Court of the United States affirmed the Eleventh Circuit’s decision. The Court held that the Copyright Act entitles a copyright owner to obtain monetary relief for any timely infringement claim, no matter when the infringement occurred. The Act’s statute of limitations establishes a three-year period for filing suit, which begins to run when a claim accrues. That provision establishes no separate three-year limit on recovering damages. If any time limit on damages exists, it must come from the Act’s remedial sections. But those provisions merely state that an infringer is liable either for statutory damages or for the owner’s actual damages and the infringer’s profits. There is no time limit on monetary recovery. So a copyright owner possessing a timely claim is entitled to damages for infringement, no matter when the infringement occurred. View “Warner Chappell Music, Inc. v. Nealy” on Justia Law

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