Reed Elsevier, Inc. v. Muchnick
United States Supreme Court
559 U.S. 154 (2010)
Following the Supreme Court's decision in a separate case addressing freelance authors' copyright infringement claims against publishers, related stayed lawsuits were consolidated, and the district court certified a settlement class of freelance authors with allegedly infringed copyrights, some of whom had registered their copyrights with the Register of Copyrights before suing and some who had not. Objecting class members, including Irvin Muchnick (defendant), challenged the certification; the court of appeals ordered briefing specifically on whether Section 411(a)'s registration requirement was jurisdictional, and ultimately held the district court had lacked jurisdiction to certify the class or approve the settlement given the unregistered copyrights involved; both sides petitioned for certiorari.
Whether Section 411(a) of the Copyright Act, requiring registration of copyrights before infringement actions may be brought, imposes a jurisdictional limitation on instituting a copyright-infringement suit.