Lexplug logoLexplug

Williams v. Crichton

Court of Appeals for the Second Circuit
1996 WL 279898, 84 F.3d 581 (1996)
ELI5:

Rule of Law:

Copyright protection extends only to the specific expression of an idea, not the idea itself. Similarities between works that are based on unprotectible general ideas or common, expected elements known as 'scenes a faire' are insufficient to support a claim of copyright infringement.


Facts:

  • Between 1985 and 1988, Geoffrey T. Williams wrote and copyrighted four children's books, known as the 'Dinosaur World' series.
  • The books are set in 'Dinosaur World,' a modern, man-made animal park where visitors can safely observe living dinosaurs.
  • In 'Lost in Dinosaur World,' a young boy named Tim gets separated from his family during a train tour of the park and must evade a dangerous allosaur.
  • In 'Explorers in Dinosaur World,' siblings Peter and Wendy visit a new island attraction called Pangaea, where a perimeter fence breaks, allowing a pack of deinonychus to escape.
  • Michael Crichton wrote the novel 'Jurassic Park,' also featuring a theme park with cloned dinosaurs on a remote island called Isla Nublar.
  • In 'Jurassic Park,' a park tour is disrupted when a corrupt employee sabotages the security systems, leading to the escape of dangerous dinosaurs like the tyrannosaurus rex and velociraptors.
  • The characters in 'Jurassic Park' are hunted by the escaped dinosaurs as they try to survive and restore order to the island.
  • Universal City Studios, Amblin Entertainment, and Steven Spielberg produced a feature film based on Crichton's novel.

Procedural Posture:

  • Geoffrey T. Williams filed a copyright infringement lawsuit against Michael Crichton and other appellees in the U.S. District Court for the Southern District of New York (a federal trial court).
  • The appellees filed a motion for summary judgment, arguing that the works were not substantially similar as a matter of law.
  • The district court granted the motion for summary judgment in favor of the appellees, dismissing Williams's case.
  • Williams, as the appellant, appealed the district court's decision to the United States Court of Appeals for the Second Circuit.

Locked

Premium Content

Subscribe to Lexplug to view the complete brief

You're viewing a preview with Rule of Law, Facts, and Procedural Posture

Issue:

Are the 'Jurassic Park' novel and movie substantially similar to the protectible expression in the 'Dinosaur World' children's books for the purpose of establishing copyright infringement?


Opinions:

Majority - Oakes, Senior Circuit Judge

No. The 'Jurassic Park' works are not substantially similar to the protectible elements of the 'Dinosaur World' books. Copyright law does not protect an idea, only its expression, and any similarities between the works are either unprotectible ideas, such as a dinosaur zoo, or are 'scenes a faire'—stock elements that are indispensable or standard in the treatment of a given topic. The court reasoned that while both series are set in dinosaur parks, this concept is an unprotectible idea. Elements like electrified fences, automated tours, and dinosaur nurseries are common 'scenes a faire' that naturally flow from the concept of a dinosaur park. Furthermore, the 'total concept and feel' of the works are fundamentally different: Williams's books are light-hearted children's adventures, whereas 'Jurassic Park' is a dark, complex techno-thriller for adults exploring themes of hubris and corporate greed. The characters, plots, and pacing are also too dissimilar to support a finding of infringement when only the protectible elements are compared.



Analysis:

This decision strongly reinforces the idea/expression dichotomy and the 'scenes a faire' doctrine as crucial filters in copyright analysis. It establishes that courts will meticulously separate unprotectible general themes and stock elements from a work before comparing it to another for substantial similarity. This precedent makes it significantly more difficult for a plaintiff to win an infringement case based on broad conceptual or setting-based similarities, especially within established genres. The ruling protects authors from litigation when they use common tropes, ensuring that the building blocks of storytelling in a particular genre remain available to all creators.

🤖 Gunnerbot:
Query Williams v. Crichton (1996) directly. You can ask questions about any aspect of the case. If it's in the case, Gunnerbot will know.
Locked
Subscribe to Lexplug to chat with the Gunnerbot about this case.

Unlock the full brief for Williams v. Crichton