defenses

Day v. Crosby

Issues

Whether after an individual files a habeas corpus petition in federal court, and the State admits in its answer that the petition was filed within the statute of limitations, the State has then waived a statute of limitations defense to a petition, which in fact was not timely filed.
 
Whether the district court, after asking the State to file an answer to a habeas petition, and after the State's answer is filed, can then dismiss the habeas petition of its own volition under Habeas Rule 4.

 

Patrick Day is currently incarcerated in the state of Florida, serving a 55-year sentence for second-degree murder. Florida State Courts affirmed his conviction, and in 2003 Day petitioned for habeas corpus review in United States District Court. Under 28 U.S.C. 2254, Day was allowed to petition for a writ of habeas corpus, but the habeas rules provide a statute of limitations for filing the writ, and allows a district court to dismiss the petition sua sponte (or on its own volition) for any one of a number of reasons. In fact, Day's petition was late, but the district court did not dismiss the petition for this reason until after it asked for the State to file a response to Day's petition. In its response the state failed to raise the statute of limitations defense. In this case the Supreme Court must decide whether the State waived its statute of limitations defense when it failed to raise the defense in its responsive pleading and whether the district court was correct in dismissing the petition sua sponte even after the State erroneously admitted Day's petition was timely in its response. The case raises legal and policy considerations, especially in regard to the federal review of otherwise final state court criminal decisions.

Questions as Framed for the Court by the Parties

Does the State waive a limitations defense to a habeas corpus petition when it fails to plead or otherwise raise that defense and expressly concedes that the petition was timely?
 
Does Habeas Rule 4 permit a district court to dismiss a habeas petition sua sponte after the State has filed an answer based on a ground not raised in the answer?
State Court Proceedings
 
A Florida jury convicted Patrick Day of second degree murder and sentenced him to prison in September 1998. Brief for the Petitioner ("Pet'r"). at 3. Day appealed his conviction to the Florida First District Court of Appeal, which affirmed the sentence on December 21, 1999. Respondent's Brief on the Merits ("Respt") at 1. Day did not file a petition for certiorari to appeal the decision to the United States Supreme Court, thereby allowing the March 20, 2000 deadline to pass. Id.
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Petrella v. Metro-Goldwyn-Mayer, Inc.

Issues

Can the laches defense be raised to bar all remedies for copyright claims filed within the three-year statute of limitations prescribed by Congress?

Frank Petrella was the screenwriter behind the critically acclaimed 1980 film Raging Bull. In 1978, United Artists Corporation, a subsidiary of Respondent Metro-Goldwyn-Mayer Studios (“MGM”), acquired the rights to the screenplay. When Frank Petrella died in 1981, the renewal rights passed to his heirs. His daughter, Petitioner Paula Petrella (“Petrella”), renewed the copyright in 1991. Over the next two decades, Petrella and MGM engaged in a series of communications, during which Petrella accused MGM of infringing her copyright. Petrella filed suit in 2009; pursuant to the three-year statute of limitations of the Copyright Act, the suit only involved claims arising from 2006 on. The Ninth Circuit Court of Appeals upheld the district court’s decision to bar Petrella’s copyright claims according to the non-statutory doctrine of laches, an equitable defense that bars claims filed too late. The Supreme Court’s ruling in this case will impact not only how quickly plaintiffs must bring copyright claims, but also the extent to which equitable defenses may apply to an area regulated by Congress. 

Questions as Framed for the Court by the Parties

Whether the non statutory defense of laches is available without restriction to bar all remedies for civil copyright claims filed within the three-year statute of limitations prescribed by Congress, 17 U.S.C. § 507(b)?

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Facts

Jake LaMotta, a retired professional boxer, and his long-time friend Frank Petrella collaborated on a book and two screenplays about LaMotta’s life and boxing career.  See Petrella v. Metro-Goldwyn-Mayer, Inc., 695 F.3d 946, 949 (9th Cir.

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