Supreme Court rules federal courts have jurisdiction over copyright settlements

[JURIST] The US Supreme Court [official website; JURIST news archive] on Tuesday ruled [opinion, PDF] in Reed Elsevier v. Muchnick [Cornell LII backgrounder; JURIST report] that a federal law [14 USC § 411(a) text] requiring copyright holders to register their works before suing for copyright infringement does not remove federal court jurisdiction if the copyright holder failed to register. The US Court of Appeals for the Second Circuit had invalidated [opinion, PDF] a lower court's approval of a settlement in a class action lawsuit on the grounds that the court lacked jurisdiction. In reversing that decision, Justice Clarence Thomas wrote:


Subject to certain exceptions, the Copyright Act (Act) requires copyright holders to register their works before suing for copyright infringement. In this case, the Court of Appeals for the Second Circuit held that a copyright holder's failure to comply with § 411(a)'s registration requirement deprives a federal court of jurisdiction to adjudicate his copyright infringement claim. We disagree. Section 411(a)'s registration requirement is a precondition to filing a claim that does not restrict a federal court's subject-matter jurisdiction.

Justice Ruth Bader Ginsburg filed an opinion concurring in part and concurring in the judgment, joined by Justices John Paul Stevens and Stephen Breyer. Justice Sonia Sotomayor took no part in deciding the case.

The case arose when a group of freelance writers filed a class action lawsuit against a group of publishers alleging copyright infringement for electronically reproducing their work without permission. The parties settled the suit with the district court's approval. When some of the plaintiffs objected to the settlement, they appealed to the Second Circuit, which ruled sua sponte that the federal court lacked jurisdiction over the case.


 

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