BELL v. CARMEN COMMERCIAL REAL ESTATE SERVICES

CourtDistrict Court, S.D. Indiana
DecidedAugust 25, 2020
Docket1:16-cv-01174
StatusUnknown

This text of BELL v. CARMEN COMMERCIAL REAL ESTATE SERVICES (BELL v. CARMEN COMMERCIAL REAL ESTATE SERVICES) is published on Counsel Stack Legal Research, covering District Court, S.D. Indiana primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
BELL v. CARMEN COMMERCIAL REAL ESTATE SERVICES, (S.D. Ind. 2020).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF INDIANA INDIANAPOLIS DIVISION

RICHARD N. BELL, ) ) Plaintiff, ) ) v. ) No. 1:16-cv-01174-JRS-MPB ) CARMEN COMMERCIAL REAL ESTATE ) SERVICES, ) ) Defendant. )

Order

Between 2011 and 2019, Plaintiff Richard N. Bell filed dozens of copyright in- fringement suits in this district, all arising from the defendants' alleged publication of photographs of the Indianapolis skyline. See Bell v. Vacuforce, LLC, 908 F.3d 1075, 1077 (7th Cir. 2018) ("Bell has prosecuted dozens of similar copyright lawsuits be- fore"). This one went to trial by jury. The jury found that Bell did not prove that he "authored the Indianapolis Skyline Photo, that he owns a copyright in it, and that he registered it with the Copyright Office." (Jury Verdict ¶ 1, ECF No. 135.) Accordingly, judgment was entered in favor of Defendant Carmen Commercial Real Estate Services. (Judgment, ECF No. 140.) Bell now moves for a new trial, (ECF No. 141), and Defendant moves for attorney's fees and costs, (ECF No. 145). I. Bell's Motion for a New Trial Bell testified that he took the daytime photograph of the Indianapolis skyline in March or May 2000, while he worked at the law firm Cohen & Malad, and that the

photograph was posted to Cohen & Malad's website. (Tr. Vol. 1 at 125:1–3.) In an- other of Bell's cases in this district, Bell v. Maloney, Case No. 1:16-cv-1193, the de- fendant contended that Bell took the photograph as a work made for hire, such that Cohen & Malad, not Bell, was the photograph's author under the Copyright Act. See 17 U.S.C. § 201(b). After a bench trial in that case, Judge Young held that the de- fendant lacked standing to assert that the photograph was a work made for hire.

In seeking a new trial in this case, Bell contends that the Court erred in allowing Defendant to assert that the photograph was a work made for hire, and in giving the jury an instruction on ownership that incorporated work-made-for-hire language. (Pl.'s Mem. Supp. Mot. New Trial, ECF No. 142.) Specifically, Bell argues (1) that Defendant should not have been allowed to raise the work-made-for-hire issue (prin- cipally for lack of standing), (2) that the evidence adduced at trial was insufficient to warrant inclusion of the work-made-for-hire language in the ownership instruction,

and (3) that the instruction wrongly allocated the burden of proof to Bell on the work- made-for-hire issue. (Pl.'s Mem. 2–4, ECF No. 142; Pl.'s Suppl. Br. 2, ECF No. 151.) Defendant responds that it had standing to raise the work-made-for-hire issue and that Bell waived any objection to the instruction by failing to make his objection dur- ing trial. A. Legal Standard "A court may only order a new trial if the jury's verdict is against the manifest weight of the evidence, or if for other reasons the trial was not fair to the moving

party." Willis v. Lepine, 687 F.3d 826, 836 (7th Cir. 2012) (quotation marks, altera- tions, and citations omitted). Under Rule 51(c)(1), "[a] party who objects to an in- struction or the failure to give an instruction must do so on the record stating dis- tinctly the matter objected to and the grounds for the objection." Fed. R. Civ. P. 51(c)(1). "A party may assign as error . . . an error in an instruction actually given, if that party properly objected." Fed. R. Civ. P. 51(d)(1)(A).

B. Discussion Defendant proposed the jury instruction on copyright ownership containing the challenged work-made-for-hire language. (ECF No. 134 at 2.) The Court's proposed instruction substantially adopted Defendant's proposed instruction: Final Instruction No. 11 Ownership

Plaintiff "owns" a copyright in the Indianapolis Skyline Photo if, and only if,

(1) he created the Photo; and (2) he did not create the Photo within the scope of his employment at Cohen & Malad.

It is Plaintiff's burden to prove ownership of the Photo by a prepon- derance of the evidence.1

1 The sole focus of Bell's motion—and hence this Order—is the second prong of the instruction. It is, of course, possible that the jury discredited Bell's testimony and found that Bell failed to prove the first prong. (ECF No. 144-1.) The proposed instructions—including the ownership instruction— were provided to counsel after the first day of trial, and essentially combined the pattern instructions on ownership and work-for-hire. (Tr. Vol. 1 at 205:7–19.) Bell

did not object to the instruction before Defendant rested its case: THE COURT: [. . .] Any questions or modifications requested by the plaintiff -- MS. KENNEDY: No, Your Honor. THE COURT: -- to any of the instructions? (Tr. Vol. 2 at 7:10–13.) Nor did Bell object to the instruction after Defendant rested. (See generally Tr. Vol. 2 at 328:7–340:25.) Nor did Bell object to the instruction after the charge was given: THE COURT: [. . .] In addition, any objections to the jury charge that was actually given, Ms. Kennedy? MS. KENNEDY: No, Your Honor. (Tr. Vol. 2 at 365:24–366:1.) In short, not until his motion for a new trial did Bell challenge the instruction on the grounds of sufficiency of the evidence, (ECF No. 142 at 4–5), and not until his supplemental brief in support of that motion did Bell chal- lenge the instruction on the grounds of the allocation of the burden of proof, (ECF No. 151 at 2). While Bell did tender a different proposed instruction on ownership, "[m]ere tendering of proposed instructions different from the instructions given is not sufficient to preserve an objection to the instructions that are given." Walker v. Groot, 867 F.3d 799, 803 (7th Cir. 2017) (alteration and quotation marks omitted).2 Bell therefore has not preserved his objections on those grounds.

2 Bell's proposed instruction stated, "Plaintiff owns a copyright in Indianapolis Skyline Photo if he created the work." (ECF No. 129 at 6.) Bell did, however, file a motion in limine—albeit an untimely one—arguing that the "work-for-hire affirmative defense should be precluded" because it was not pleaded as an affirmative defense in Defendant's answer and because Defendant

lacked standing to raise the issue, relying on Judge Young's decision in Bell v. Malo- ney, 1:16-cv-1193-RLY-DML, ECF No. 86 (S.D. Ind. May 23, 2019). (See ECF No. 116-1.) That motion was denied. Bell contends that his motion in limine preserved his objection to the instruction and to the admission of any work-made-for-hire evi- dence.3 The denial of Bell's motion in limine was not erroneous. First, Defendant did not

waive or forfeit the argument that the photograph was a work made for hire. Defend- ant's work-made-for-hire challenge to Bell's ownership was not an affirmative defense required to be pleaded under Rule 8(c). "A few courts have (erroneously) held that the assertion by defendant of work-for-hire status is an affirmative defense. . . . As a fundamental matter, an affirmative defense arises when a defendant admits the es- sential elements of plaintiff's prima facie case but sets up other facts or legal argu- ments by way of avoidance of infringement. By contrast, an answer or other argu-

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BELL v. CARMEN COMMERCIAL REAL ESTATE SERVICES, Counsel Stack Legal Research, https://law.counselstack.com/opinion/bell-v-carmen-commercial-real-estate-services-insd-2020.