Marya v. Warner/Chappell Music, Inc. - 131 F. Supp. 3d 975 (C.D. Cal. 2015)

Rule:

Summary judgment may only be granted if the movant has shown that there was no genuine dispute as to any material fact and the movant was entitled to judgment as a matter of law.

Facts:

Plaintiffs Rupa Marya, Robert Siegel, Good Morning to You Productions Corp., and Majar Productions, LLC (collectively, "Plaintiffs") filed the present class action to declare invalid Defendants Warner/Chappell Music, Inc. ("Warner/Chappell") and Summy-Birchard, Inc.'s ("Summy-Birchard") (collectively, "Defendants") purported copyright in the famous song “Happy Birthday To You ("Happy Birthday"). Plaintiffs alleged that the Defendants did not own a copyright in the “Happy Birthday” lyrics, and that they should be compelled to return the "millions of dollars of unlawful licensing fees" they have collected by wrongfully asserting copyright ownership in the Happy Birthday lyrics. The case was now before the United States District Court for the Central District of California on the Parties’ Cross-Motions for Summary Judgment.

Issue:

1. Were defendants entitled to summary judgment?
2. Were plaintiffs entitled to summary judgment?

Answer:

1) No. 2) Yes.

Conclusion:

The court noted that summary judgment may only be granted if the movant has shown that there was no genuine dispute as to any material fact and the movant was entitled to judgment as a matter of law. According to the court, only disputes over facts that might affect the outcome of the suit under the governing law will properly preclude the entry of summary judgment. The court further noted that the moving party bore the initial responsibility to point the absence of any genuine issue of material fact. On cross-motions for summary judgment, the court must consider each motion separately to determine whether either party has met its burden with the facts construed in the light most favorable to the nonmoving party. In this case, the court held that there were triable issues of fact regarding the authorship of the “Happy Birthday” lyrics. Moreover, the court noted that even assuming the issue of authorship was resolved, the alleged authors of the song lyric did not try to obtain federal copyright protection nor did they take legal action to prevent the use of the lyrics by others, even as “Happy Birthday” became very popular and commercially valuable. The court held that defendants’ assertion that the alleged author gave Summy Co. the rights in the lyrics to exploit and protect has no support in the record. Accordingly, the court denied defendants’ motion and granted plaintiffs’ motion for summary judgment.