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Sheldon v. Metro-Goldwyn Pictures Corp.

Court of Appeals for the Second Circuit
81 F.2d 49 (1936)
ELI5:

Sections

Rule of Law:

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The Legal Principle

This section distills the key legal rule established or applied by the court—the one-liner you'll want to remember for exams.

Facts:

  • The historical 1857 trial of Madeleine Smith, a Scottish woman accused of poisoning her lover to secure a more socially acceptable marriage, became a well-known story in the public domain.
  • Plaintiffs Edward Sheldon and Margaret Ayer Barnes authored a play titled 'Dishonored Lady,' which was based on the Madeleine Smith story but featured original characters, plot developments, and scene sequences.
  • The play's heroine, Madeleine Cary, is a modern, complex woman who poisons her possessive lover, Moreno, and is ultimately saved from prosecution when a friend provides a false alibi during an informal inquiry.
  • Defendant Metro-Goldwyn Pictures Corp. negotiated to acquire the rights to 'Dishonored Lady' but ultimately declined after the Hays Office deemed the play obscene.
  • Subsequently, Metro-Goldwyn purchased the rights to a novel by Marie Belloc Lowndes, 'Letty Lynton,' which was also based on the Madeleine Smith story.
  • Metro-Goldwyn then produced a film, also titled 'Letty Lynton,' which contained numerous specific plot points, character traits, and scene sequences that were present in the play 'Dishonored Lady' but absent from both the historical account and the Lowndes novel.
  • These copied elements included a confrontation where the lover threatens to expose the heroine, the heroine finding poison at her home, the specific sequence of events in the death scene, and a final scene involving a district attorney's inquiry (rather than a trial) where the heroine is saved by a fabricated alibi.

Procedural Posture:

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How It Got Here

Understand the case's journey through the courts—who sued whom, what happened at trial, and why it ended up on appeal.

Issue:

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Legal Question at Stake

This section breaks down the central legal question the court had to answer, written in plain language so you can quickly grasp what's being decided.

Opinions:

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Majority, Concurrences & Dissents

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Analysis:

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Why This Case Matters

Get the bigger picture—how this case fits into the legal landscape, its lasting impact, and the key takeaways for your class discussion.

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