华纳查普尔音乐公司诉尼利案

This case originated from a lawsuit filed by Sherman Nealy, a music producer, against Warner Chappell Music for licensing his works without authorization. Nealy claimed the infringement started decades ago but sued within three years of discovering it. The core procedural issue was whether copyright plaintiffs can recover damages for infringements that occurred more than three years before filing suit, even if they timely sued under the discovery rule. The Eleventh Circuit held that Nealy could recover damages without any time limit. The Supreme Court granted certiorari and affirmed, resolving a circuit split. The majority opinion, authored by Justice Kagan, ruled that if a claim is timely under the discovery rule, there is no separate temporal bar on recovering retrospective damages for older infringements.

In a 6-3 decision, the Supreme Court affirmed the Eleventh Circuit. The majority held that the Copyright Act entitles a plaintiff to recover damages for any timely infringement claim, regardless of when the infringing acts occurred. Since no separate time limit on damages exists in the statute, a plaintiff who timely files under the discovery rule may obtain monetary relief for infringements dating back more than three years.

The central dispute was whether the Copyright Act's three-year statute of limitations merely limits the time to file suit (a procedural bar) or also limits the period for which retrospective monetary damages can be recovered to three years before filing. The case resolved a deep circuit split over the application of the discovery rule and the calculation of damages in copyright infringement claims.

The ruling significantly strengthens the position of copyright holders, particularly individual creators and owners of older music catalogs, by allowing them to recover potentially vast historical damages if they successfully plead the discovery rule. It has profound implications for the music industry, publishing, and digital content platforms, as defendants face increased liability exposure for long-running infringements. The decision provides clarity and uniformity in federal copyright litigation while igniting debate over the need for legislative action to impose a damages cap.