Petrella v. Metro-Goldwyn-Mayer, Inc. (12-1315)

argument 12-1315

Petrella v. Metro-Goldwyn-Mayer, Inc.

Supreme Court of the United States 1h 1m 6 speakers 8 chapters transcribed 6 days ago official recording ↗

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What is the central dispute over the Laches doctrine in Petrella v. MGM?

John G. Roberts 0:01

We'll hear argument next in case twelve, thirteen, fifteen, Petrella versus Metro Goldwyn Mayer. Mr Beebas?

Nicholas Bronni 0:08

Mr. Chief Justice, and may it please the Court, This court has never applied latches to constrict a federal statute limitations and rejected such a claim just four years ago. Latches cannot bar these copyright infringement claims for four reasons. First, under the separate accrual rule, these claims are timely. Respondents committed these discrete wrongs from two thousand six on, but would use petitioners' failure to challenge earlier wrongs to foreclose these later claims before they even arose. Second, Latches is a gap filler, but Congress filled this gap with a bright line statute of limitations. Third, Congress chose a clear, predictable timeliness rule. And fourth, injunctive relief must remain available to protect petitioners' property right against ongoing violations, lest respondents effectively get a compulsory license for free for the next four decades.

Unknown 1:02

Let's let's take your second point. What a statute of limitation says is not that you Uh or Or Scot free within the statute of limitations period. It it simply is a negative. It says you can't be sued beyond that, right?

Nicholas Bronni 1:22

Yes,

Unknown 1:22

wording

Nicholas Bronni 1:23

of the

Unknown 1:23

financial

Nicholas Bronni 1:24

limitations.

Unknown 1:28

If if we adopted uh The position of the other side. There's nothing that would cause the statute of limitations to be frustrated.

Nicholas Bronni 1:39

This is not purely about the text, but about the background principle of equity that Latches is. Latches' domain was as a gap filler where there was no print no timeliness rule. Congress has occupied the field with a timeliness rule here and displaced it. That's why Latches developed inequity to compensate for the absence of limitations here is.

Unknown 2:00

Yes, but it continued to be used in equity, even when there were limitations, period, didn't it? It may it may have started that way, but that's that was certainly not its only use.

Nicholas Bronni 2:08

Not where there was a binding, a federal one. Where there was an analogous one that was borrowed loosely from a state in diversity, federal courts understood themselves to have flexibility to vary from the state limitation period because it wasn't federal law. Well, it was Federal law. If the Federal law adopted it, it was Federal law. This was in the pre-Eerie days where there was understanding that there was a general federal common law and equity that those cases were decided. The this court in Homework versus Armbrecht understood this almost as a chevron type argument. Has Congress spoken to the timeliness issue? If yes, Holmberg says the congressional statute is definitive. If not, Holmg says, then its silence delegates the matter to, quote, judicial implication.

Nicholas Bronni 2:51

And then there's some judicial flexibility on timeliness issues. There's no question that non timeliness doctrines can cut claims off within the limitations period, but not the timeliness doctrine of latches.

Samuel A. Alito 3:02

Should we see anything in the particular way this provision is worded? It says no civil action shall be maintained under the provisions of this title unless it is commenced within three years after the claim uh accrued. It doesn't say any civil action may be maintained if it is commenced within three years after the claim occurred.

Nicholas Bronni 3:23

Yes, Your Honor, that's So it

Samuel A. Alito 3:24

doesn't you know, it says you it says you can't do it unless it's within three years. But it doesn't say that if it's within three years you're home free.

Nicholas Bronni 3:32

Yes, Your Honor. That's why I said it's not strictly a textual argument. It's about the domain of latches and the congressional understanding of limitations periods. That's what how this court read them in the Ledbetter case, if I might quote A freestanding violation may always be charged within its own charging period, regardless of its connection to other violations. We repeated the same point more recently in Morgan. Quote, the existence of past acts and the employees' prior knowledge of their occurrence dot dot dot does not bar employees from filing charges about related discrete acts, so long as the acts are independently discriminatory, and charges addressing those acts are themselves timely filed.