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Brown v. Time Warner, Inc.

Citation: 287 F. Supp. 3d 380Docket: 17 Civ. 2293 (LLS)

Court: District Court, S.D. Illinois; December 5, 2017; Federal District Court

Narrative Opinion Summary

The case involves a copyright infringement suit brought by Randy Brown against defendants including Time Warner Inc., Turner Broadcasting System, Inc., and others, regarding alleged similarities between Brown's short story, 'Thank You, Jesus,' and the television series 'Black Jesus' aired on Adult Swim. Brown contended that the series copied protectable elements of his story, which features a character named Jesus involved in a church-related narrative. The court, however, granted the defendants' motion to dismiss, ruling that no substantial similarity existed between the protectable expressions of the two works. The judgment emphasized that copyright law protects the specific expression of ideas rather than the ideas themselves, and found that the abstract concept of an African American Jesus engaging in 'un-Jesuslike' behavior was not enough to constitute infringement. Further distinguishing the two works, the court noted significant differences in plot, characterization, setting, and thematic content. 'Thank You, Jesus' was set in a rural backdrop focusing on themes of greed and faith, while 'Black Jesus' was set in urban Compton, exploring themes of forgiveness and social issues. Consequently, the claim was dismissed due to the lack of substantial similarity in the protected elements of expression.

Legal Issues Addressed

Copyright Infringement and Substantial Similarity

Application: The court found that there is no substantial similarity between the protectable elements of Randy Brown's short story and the television series 'Black Jesus', leading to the dismissal of the copyright infringement complaint.

Reasoning: In the case at hand, there is no substantial similarity between 'Thank You, Jesus' and 'Black Jesus,' despite both featuring an African American male protagonist named Jesus.

Differentiation of Plot and Characterization

Application: The court distinguished the unique plot and characterization in each work, despite superficial similarities, to emphasize the lack of protectable expressive overlap necessary for infringement.

Reasoning: The plots, while superficially comparable, diverge significantly upon closer examination.

Protection of Expression versus Ideas

Application: The legal principle that copyright law protects the expression of ideas rather than the ideas themselves was pivotal in determining that the similarities in abstract concepts between the works did not constitute infringement.

Reasoning: Copyright law protects the specific expression of ideas rather than the ideas themselves. When comparing two works, similarity at an abstract level does not constitute infringement.

Scenes a Faire Doctrine

Application: The court applied the scenes a faire doctrine, which excludes from protection elements that naturally arise from a particular setting, noting the lack of protection for general themes shared by the two works.

Reasoning: Scenes a faire, which are events that arise naturally from a particular setting, also lack copyright protection, as illustrated by case law such as Williams v. Crichton and Walker v. Time Life Films.