Twentieth Century-Fox Film Corp v. MCA, Inc.
715 F.2d 1327 (1983)
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Rule of Law:
Summary judgment is inappropriate in a copyright infringement action if reasonable minds could differ on the question of whether the two works at issue are substantially similar in their ideas and expression of those ideas.
Facts:
- In 1976, Lucasfilm, Ltd. published the book "Star Wars."
- In 1977, Twentieth Century-Fox produced and distributed the motion picture "Star Wars," which became a major commercial success.
- The following year, in 1978, Universal Studios, Inc., a subsidiary of MCA, Inc., produced the motion picture and television series "Battlestar: Galactica."
- ABC Television, Inc. televised the "Battlestar: Galactica" series.
- The creators of "Star Wars" identified numerous alleged similarities between the two works, including a central conflict between democratic and totalitarian forces, a young hero guided by a wise older man, the destruction of a planet, the imprisonment of a heroine, and a climactic attack on the totalitarian headquarters.
Procedural Posture:
- Twentieth Century-Fox Film Corp. sued MCA, Inc., Universal Studios, Inc., and ABC, Inc. in federal district court for copyright infringement.
- The complaint was amended to join Lucasfilm, Ltd. as a co-plaintiff.
- Defendants (MCA, Universal, and ABC) moved for partial summary judgment, arguing the works were not substantially similar as a matter of law.
- For the purposes of the motion, defendants admitted to having access to the "Star Wars" works and did not contest the validity of the plaintiffs' copyrights.
- The district court (trial court) granted the defendants' motion for partial summary judgment.
- Plaintiffs (Fox and Lucasfilm), as appellants, appealed the district court's decision to the United States Court of Appeals for the Ninth Circuit.
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Issue:
Is a grant of summary judgment for the defendant in a copyright infringement case appropriate where the works are allegedly so dissimilar that no material issue of fact exists regarding substantial similarity?
Opinions:
Majority - Tang, J.
No. A grant of summary judgment is inappropriate because reasonable minds could differ as to whether the two works are substantially similar. The court's role in reviewing a summary judgment motion is to determine if a genuine issue of material fact exists, not to resolve the factual dispute itself. Viewing the evidence in the light most favorable to the plaintiffs, the court concluded that the similarities between "Star Wars" and "Battlestar: Galactica" raised a genuine factual issue regarding whether the expression of the idea, not just the idea itself, was copied. Because the question of substantial similarity is a close one that should be resolved by a trial, granting summary judgment was improvident.
Analysis:
This decision reinforces the traditional disfavor of summary judgment in copyright infringement cases, particularly on the fact-intensive question of substantial similarity. It clarifies that a court's role at the summary judgment stage is not to substitute its own judgment for that of a jury, but to act as a gatekeeper. By reversing the lower court, the Ninth Circuit emphasized that as long as there is a plausible, debatable issue of similarity between two works, the copyright holder is entitled to have that question decided by a trier of fact at trial. This precedent makes it more difficult for defendants to obtain early dismissal of copyright claims unless the works are so patently dissimilar that no reasonable jury could find infringement.
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