Justia Copyright Opinion Summaries

The case concerns Frederick Allen, a videographer, and his company, Nautilus Productions, who documented the excavation of the Queen Anne’s Revenge, the sunken pirate ship of Blackbeard, off the North Carolina coast. Allen registered copyrights for many years of video footage he recorded during the recovery project. The State of North Carolina and its Department of Natural and Cultural Resources entered into agreements related to the salvage operation. Allen alleged that state officials infringed his copyrights by using his footage online and in state publications without permission, and that the state passed a law, N.C. Gen. Stat. § 121-25(b), which Allen argued authorized this infringement.The United States District Court for the Eastern District of North Carolina initially dismissed some claims but allowed Allen’s claims for declaratory judgment and copyright infringement to proceed, finding Congress had validly abrogated state sovereign immunity under the Copyright Remedy Clarification Act (CRCA). On appeal, the United States Court of Appeals for the Fourth Circuit reversed, holding that the CRCA did not validly abrogate state sovereign immunity, and the Supreme Court affirmed. Allen then voluntarily dismissed his remaining claims against the only non-governmental defendant, closing the case.Despite these rulings, the district court in 2021 allowed Allen to reopen the case, permitting him to amend his complaint based on a new constitutional theory stemming from United States v. Georgia, seeking as-applied, case-by-case abrogation of state sovereign immunity. In 2024, the district court denied sovereign immunity on this new claim, allowing it to proceed. The North Carolina defendants appealed.The United States Court of Appeals for the Fourth Circuit held that the district court abused its discretion in reopening the litigation under Rule 54(b) rather than Rule 60(b), where no extraordinary circumstances justified such relief. The appellate court reversed the order reopening the case, vacated the subsequent 2024 ruling as moot, and remanded with instructions to close the litigation and dismiss all claims against the North Carolina defendants with prejudice. View "Allen v. Stein" on Justia Law

A dispute arose from the design and installation of cabinetry in a luxury home in Charleston, South Carolina. Design Gaps, Inc., owned by David and Eva Glover, had a longstanding business relationship with Shelter, LLC, a general contractor operated by Ryan and Jenny Butler. After being dissatisfied with Design Gaps’ performance, the homeowners, Dr. Jason and Kacie Highsmith, and Shelter terminated their contract with Design Gaps and hired Distinctive Design & Construction LLC, owned by Bryan and Wendy Reiss, to complete the work. The Highsmiths and Shelter initiated arbitration against Design Gaps, which led to the arbitrator ruling in favor of the homeowners and Shelter on their claims, and against Design Gaps on its counterclaims, including those for copyright infringement, tortious interference, and unfair trade practices.After the arbitration, Design Gaps sought to vacate the arbitration award in the United States District Court for the District of South Carolina, but the court instead confirmed the award. Concurrently, Design Gaps filed a separate federal lawsuit against several parties, including some who were not part of the arbitration. The defendants moved to dismiss, arguing that res judicata and collateral estoppel barred the new claims, or alternatively, that the claims failed on other grounds such as the statute of limitations and laches. The district court agreed, dismissing most claims based on preclusion or other legal bars, and granted summary judgment on the remaining claims.The United States Court of Appeals for the Fourth Circuit reviewed the district court’s decisions. The court held that res judicata and collateral estoppel applied to bar most of Design Gaps’ claims, even against parties not directly involved in the arbitration but in privity with those who were. For the remaining claims, the court found they were properly dismissed on grounds such as the statute of limitations, waiver, or laches. The Fourth Circuit affirmed the district court’s judgment in full. View "Design Gaps, Inc. v. Distinctive Design & Construction LLC" on Justia Law

Jason and Kacie Highsmith hired Shelter, LLC to manage a home renovation project and later contracted with Design Gaps, Inc. to design and install cabinets and closets. The contracts required arbitration for disputes but did not specify completion dates. Design Gaps failed to meet multiple promised deadlines, leading the Highsmiths to terminate the contracts and hire another company. The Highsmiths shared Design Gaps' copyrighted drawings with the new contractor. They then filed for arbitration, alleging breach of contract and other claims, while Design Gaps counterclaimed for various issues, including copyright infringement.The arbitrator held a three-day hearing, during which the Highsmiths presented multiple witnesses, while Design Gaps only presented David Glover. The arbitrator found in favor of the Highsmiths, awarding them damages and attorney’s fees, and denied Design Gaps' counterclaims, including the copyright claim, citing fair use and lack of evidence for copyright registration.Design Gaps petitioned the United States District Court for the District of South Carolina to vacate the arbitration award, arguing the arbitrator disregarded the law and failed to issue a reasoned award. The district court denied the petition and confirmed the arbitration award, also granting the Highsmiths' motion for attorney’s fees.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court dismissed the appeal, citing lack of federal jurisdiction based on the precedent set in Friedler v. Stifel, Nicolaus, & Co., which held that federal courts do not have jurisdiction over motions to vacate arbitration awards unless there is an independent basis for federal jurisdiction beyond the Federal Arbitration Act. The court concluded that the petition did not meet this requirement. View "Design Gaps, Inc. v. Shelter, LLC" on Justia Law