The Ray Charles Found. v. Robinson, No. 13-55421 (9th Cir. 2015)Annotate this Case
The Foundation, the sole beneficiary of Ray Charles' estate, filed suit to challenge his heirs' purported termination of copyright grants that Charles conferred while he was alive. The district court dismissed the suit for lack of jurisdiction. The court concluded that the suit meets the threshold requirements of constitutional standing and ripeness, the argument that the Foundation may be a beneficial owner lends no support to its claim to standing; the Foundation is a real party in interest and has third-party standing; under the zone-of-interests test, the Foundation properly asserts its own claims where termination, if effective, would directly extinguish the Foundation’s right to receive prospective royalties from the current grant; and the Foundation is indeed a party whose injuries may have been proximately caused by violations of the statute. Accordingly, the court reversed the district court's judgment.
Court Description: Copyright. Reversing the district court’s dismissal for lack of jurisdiction, the panel held that the Ray Charles Foundation, the sole beneficiary of Ray Charles’s estate, had standing to challenge the validity and effectiveness of notices of termination of copyright grants conferred by Charles to the predecessor of Warner/Chappell Music. The panel held that the Foundation had Article III standing and that the suit was ripe. The panel held that the Foundation did not have standing to challenge the termination notices as a beneficial owner. Nonetheless, the Foundation was a real party in interest because the termination notices affected its right to royalties, and its claims fell within the statutory zone of interests. Accordingly, it had standing to sue to challenge whether the underlying works were works made for hire and thus not subject to the termination THE RAY CHARLES FOUND. V. ROBINSON 3 provisions of 17 U.S.C. §§ 203 and 304(c). The panel remanded the case for further proceedings.