Citation: 33 U.S. 591 (1834)
Court: U. S. Supreme Court
Bench: Chief Justice John Marshall Associate Justices William Johnson · Gabriel Duvall Joseph Story · Smith Thompson John McLean · Henry Baldwin
Henry Wheaton (“Wheaton”) was the reporter of decisions of the United States Supreme Court between 1816 and 1827. During his tenure, he authored twelve volumes of Supreme Court decision reports. His successor, Richard Peters (“Peters”), took it upon himself to reprint Wheaton’s work more briefly to reduce the cost of the book. Wheaton sued Peters in the Trial Court alleging that Peters violated his copyright by selling shortened versions of his work and sought an injunction to prevent its sale. Peters denied this and claimed that Wheaton did not possess valid copyright because he did not prudently satisfy all the federal statutory requirements crucial for availing copyright protection. The Trial Court conceded with Peters’ argument and dismissed the case. Wheaton then went ahead and appealed to the Supreme Court.
Does Wheaton’s work qualify for copyright protection under the law?
Copyright Act of 1790
The US Supreme Court, in this case, made three rulings that changed the face of American copyright law. It rejected Wheaton’s argument that he owned perpetual copyright over his work under Pennsylvania's common law. Although Wheaton adhered to Pennsylvania procedure to secure a copyright, it was held that its common law failed to address copyrights and thus could not grant protection to written works.
The Court further rejected Wheaton’s argument that he adhered to appropriate provisions of the federal copyright law and the argument that his work was eligible for copyright protection, and instructed the Circuit Court to hold a trial on the same.
The US copyright law in 1802 necessitated certain measures to secure copyright. A book was initially to be deposited with the clerk of the requisite District Court, the record made by the clerk ought to have been inserted in the first or the second page, public notice given to newspapers, and within six months after publication, a copy of the book must have been deposited in the State Department. Wheaton, according to the Supreme Court, had only completed the first two steps, due to which his work was not entitled to copyright.
Lastly, the Court ruled that no reporter could have any copyright in the Court’s opinion put down in a written format. This final rule gave this case its landmark status because it was essential to the free flow of public information. After all, if Wheaton was allowed to control this flow through copyright, then other private parties could do so too, thus restricting its dissemination.
The Circuit Court ruled that Wheaton had satisfied the copyright formalities, after which Peter appealed. However, while the appeal was pending, both Peters and Wheaton passed away. Later on, the case was settled when a jury determined that Wheaton had copyright over his notes and appendices. Peter’s estate paid Wheaton’s estate a sum of four hundred U. S. dollars.
This decision by the U.S. Supreme Court delineated the differences between copyrights under common law and federal statutory law. It turned out to be the first landmark copyright decision by the U. S. Supreme Court. It established the basic tenets of the U. S. copyright law, declaring that the statutory criteria to secure copyright must be strictly adhered to and that copyright itself existed to progress society and not only the creator. Finally, the prevention of information monopolization using copyright law was heralded by this decision.