Clinton v. Houston
- Laura Swain
- 1:22-cv-10188
- U.S. District Court · Southern District of New York
- 3
In Clinton v. Houston, Chief Judge Swain dismissed Ms. Clinton’s copyright action as untimely and denied her fee-free status for an appeal.
Ms. Eloise Clinton’s copyright action was dismissed as time barred. Whitney Houston, Dolly Parton, and Arista Records were the named defendants. Clinton was denied fee-free status for an appeal.
What happened
In Clinton v. Houston, Ms. Eloise Clinton alleged that she created a song in 1985 and that Whitney Houston and Dolly Parton later used her music in “I Will Always Love You.” The court treated the complaint as a copyright claim against Houston, Parton, and Arista Records.
The court explained that copyright claims generally must be filed within three years. Because Clinton said she learned of the alleged infringement in 1992 but did not file this case until November 30, 2022, the court found the claim untimely. Clinton’s lack of knowledge about the filing deadline did not justify extending the deadline.
The court dismissed the action for failure to state a claim. Chief Judge Laura Taylor Swain also denied Clinton’s fee-free status for an appeal, finding that an appeal would not be taken in good faith, and directed the Clerk of Court to enter judgment.
The detailed version
- Clinton v. Houston · No. 1:22-cv-10188
- Laura Swain
- May 10, 2023
Background
Ms. Eloise Clinton alleged that she created the song “To Love You Share My Rainbow” in 1985. She alleged that, in 1992, she heard Whitney Houston use her music in “I Will Always Love You,” which Houston sang for the soundtrack of The Bodyguard. Clinton also alleged that Dolly Parton sang the same song. The court construed the complaint as asserting claims under the Copyright Act.
The court had previously ordered Clinton to explain why the action should not be dismissed as time barred. Clinton responded that she had not filed the case on time because she was unaware of the applicable statute of limitations. She filed the action on November 30, 2022.
Court’s Analysis
The court stated that the Copyright Act has a three-year statute of limitations. Based on Clinton’s allegation that she learned of the alleged infringement in 1992, the court concluded that the limitations period expired sometime in 1995.
The court considered whether equitable tolling could extend the deadline. Equitable tolling is a limited doctrine that can extend a filing deadline when a person acted with reasonable diligence but extraordinary circumstances prevented a timely filing. The court found that Clinton did not show reasonable diligence from 1992 through November 30, 2022. It also held that not knowing about the three-year deadline was insufficient to establish an extraordinary circumstance.
Because the time bar was apparent from Clinton’s own filings, the court dismissed the complaint for failure to state a claim. This was a dismissal under the rule allowing dismissal when a complaint does not state a legally sufficient claim for relief; the court did not decide whether Clinton’s underlying copyright allegations were proved.
Disposition
The court dismissed the action for failure to state a claim under 28 U.S.C. § 1915(e)(2)(B)(ii). The action had been filed without prepaying the filing fee under 28 U.S.C. § 1915(a)(1). The court certified under § 1915(a)(3) that any appeal would not be taken in good faith and denied fee-free status for purposes of an appeal. It directed the Clerk of Court to enter judgment.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.