The question
Whether, under the Copyright Act's three-year statute of limitations, a copyright owner with a timely infringement claim may recover damages for infringements that occurred more than three years before the suit was filed.
Warner Chappell Music, Inc. v. Nealy
What the Court decided
The Court affirmed the Eleventh Circuit and held that a copyright owner with a timely infringement claim may recover monetary relief no matter when the infringement occurred. The Copyright Act sets a three-year period for filing suit but imposes no separate three-year cap on damages. The Act's remedial sections state only that an infringer is liable for statutory damages or for the owner's actual damages and the infringer's profits, with no time limit on recovery.
How the justices split
6-3The Court's opinion
Kagan, joined by Roberts, Sotomayor, Kavanaugh, Barrett, Jackson
The Copyright Act's statute of limitations sets a three-year window to file suit that begins when a claim accrues, but establishes no separate three-year limit on recovering damages. Any time limit on damages would have to come from the Act's remedial sections, and those sections impose none. A copyright owner with a timely claim may therefore recover damages regardless of when the infringement occurred. Petrella does not support a three-year damages cap, because its statement about relief running three years back merely described how the limitations provision worked on that case's facts, where the plaintiff could not use the discovery rule.
Dissenting
Gorsuch, joined by Thomas, Alito
The dissent would not resolve the damages question on the assumption the majority made. It filed a dissenting opinion joined by Thomas and Alito.
How we know · 5 sourced claims
The Court held that the Copyright Act entitles a copyright owner to monetary relief for any timely infringement claim, no matter when the infringement occurred.
Source: syllabus, Held
The Act's three-year statute of limitations sets a period for filing suit but establishes no separate three-year limit on recovering damages.
Source: syllabus, Held
The Court assumed without deciding that a claim accrues upon its discovery.
Source: syllabus, Held
The Court determined that its earlier decision in Petrella does not support a three-year damages cap.
Source: syllabus, Held
Kagan delivered the opinion of the Court, joined by Roberts, Sotomayor, Kavanaugh, Barrett, and Jackson; Gorsuch filed a dissent joined by Thomas and Alito.
Source: syllabus, lineup