Self-Realization Fellowship Church, a California Corporation,plaintiff-Appellant v. Ananda Church of Selfrealization, a California Corporation Fellowship of Inner Communion, a California Corporation James Walters, AKA Sri Kriyananda

Citation: 206 F.3d 1322Docket: 97-17407

Court: Court of Appeals for the Ninth Circuit; March 22, 2000; Federal Appellate Court

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The case involves a copyright dispute between Self-Realization Fellowship Church (SRF) and Ananda Church of Self-Realization, led by James Walters. SRF asserts ownership of copyrights to the works of Swami Paramahansa Yogananda, while Ananda contests the validity of these copyrights. The district court granted summary judgment in favor of Ananda. Key issues on appeal include whether Yogananda's works can be classified as "works for hire" under the 1909 Copyright Act and whether SRF can demonstrate a valid assignment of common law copyrights.

The court determined that Yogananda's writings and lectures do not qualify as works for hire or corporate works under the law, meaning common law copyrights did not automatically belong to SRF. However, it found that there are triable issues regarding the validity of purported assignments and whether some photographs might be classified as works for hire. The case is remanded for further proceedings to address these issues. Background information notes that Yogananda founded SRF in 1935 and lived there until his death in 1952, during which he created numerous works published by SRF.

In the district court, evidence was presented regarding Yogananda's relationship with Self-Realization Fellowship (SRF) and his intentions about the ownership of his works and copyrights. Yogananda assigned all his possessions to SRF through a written document on May 28, 1935, which included various personal items and intellectual properties. In 1939, he signed an SRF form relinquishing claims for compensation in return for being accepted as a worker. Although SRF obtained copyrights for most of Yogananda's published works, he retained some copyright ownership, particularly for six works he arranged to have translated into Spanish in 1951. After Yogananda's death, James Walters (Sri Kriyananda) left SRF to establish Ananda, a competing church that admitted to copying SRF's materials, prompting SRF to file a copyright infringement lawsuit in 1990. 

The initial copyrights for the works in question fell under the Copyright Act of 1909, which had a 28-year term. The holder of the common law copyright at publication—either the author or the assignee—was entitled to statutory protection, and assignments didn't require written form to be enforceable. Blanket copyrights could protect all components of a work, granting the copyright holder the same rights as if each part were individually copyrighted. However, the 1909 Act did not extend protections to sound recordings, for which SRF claims common law copyright protection under California law. This state law allows for the protection and transfer of rights in sound recordings, which were not covered federally before the 1976 Act.

The appeal involves the copyright status of works authored by Yogananda, with key issues being whether these works were 'works for hire' or produced by a 'corporate body' under the 1909 Copyright Act. The district court found that the works did not qualify as either, which is affirmed. Additionally, it concluded that there was no valid assignment of common law copyrights to Self-Realization Fellowship (SRF), but this conclusion is disputed, as SRF has raised triable issues regarding assignment.

Regarding renewal rights, it was determined that SRF could not renew copyrights for Yogananda's books since the rights revert to the author's next of kin after the initial copyright expires if the author is deceased. However, SRF is entitled to renew any valid initial copyrights related to Yogananda's articles.

SRF argues it holds valid copyrights under the 'work for hire' doctrine, which states that the employer may be considered the author if the work was created at their instance and expense. To avoid summary judgment, SRF needed to present credible evidence that Yogananda's work was done at its direction. The court found no evidence supporting that Yogananda's motivation for his writings stemmed from SRF, indicating that his works were driven by his own self-expression rather than SRF's involvement. Additionally, the relationship between SRF and Yogananda did not fit the traditional employer-employee model necessary to presume copyright ownership, nor was there evidence of SRF supervising or controlling Yogananda's work. Consequently, Yogananda's works are not classified as 'works for hire.'

The 1909 Act's renewal provision refers to works copyrighted by a "corporate body," but the court concludes that Yogananda did not create his works as part of such a body. Previous court interpretations, particularly from the Second Circuit, indicate that the "corporate body" provision applies only to works created by a collective entity, not identifiable individuals. Consequently, the district court correctly determined that SRF does not hold copyrights to Yogananda's works under this doctrine.

Even without the corporate body consideration, SRF's copyrights may still be valid if Yogananda informally assigned his common law copyrights before publication. Such assignments do not require written documentation, as established in case law. SRF presents evidence supporting its claim of an informal assignment, including a 1935 Assignment of all possessions from Yogananda, his vow of poverty, and his acquiescence to SRF's copyrighting of his works. SRF also holds initial statutory copyrights in its name, which are presumed valid under the 1909 Act due to registration.

On the other hand, Ananda argues that Yogananda retained some rights, citing evidence of copyrights obtained in his name for other works, a less-than-total renunciation of property rights in his vow of poverty, and attempts to secure copyrights in Mexico, suggesting he never intended to transfer his U.S. copyrights to SRF.

The district court found it significant that some of SRF's copyright certificates labeled SRF as the owner of a work for hire, but prior case law indicates that such descriptions are not definitive in determining copyright ownership. The court cited Urantia Foundation, which established that descriptions at registration are not conclusive, and noted that copyright law should be applied fairly rather than mechanically. The court agreed with Ananda's interpretation of Yogananda’s vow of poverty and noted that not all of Yogananda's works were copyrighted in SRF's name. The determination of whether common law copyrights were assigned to SRF involves discerning Yogananda's intent, which remains a factual question. The 1935 assignment is relevant but not decisive for Yogananda's works thereafter. The district court cannot weigh conflicting evidence or determine credibility at the summary judgment stage, yet SRF has presented enough evidence to warrant a trial on its claim of holding valid initial copyrights through an informal assignment. The court reversed the summary judgment regarding any works copied within their initial copyright terms and remanded for further proceedings.

Regarding renewal rights for writings copied during their renewal terms, SRF must prove it initially held valid copyrights and had the right to renew them. Under the 1909 Act, renewal rights typically revert to the author or their heirs, with specific exceptions. SRF does not claim the posthumous works exception applies, nor do the work for hire or corporate body exceptions apply to Yogananda's writings. The only potential exception available to SRF pertains to 'periodical, encyclopedic, and composite works.'

The district court's summary judgment in favor of Ananda regarding books copied during their renewal terms is affirmed, as these works do not qualify as periodical, composite, or encyclopedic. However, articles published in SRF's magazine are considered periodical works, for which SRF holds the copyright. Under the 1909 Copyright Act, a copyright holder could renew copyrights for periodical works, and a blanket copyright on a periodical protects its individual articles if the publisher held common law copyrights prior to publication. If SRF can prove that Yogananda informally assigned his common law copyrights for his articles, it would be entitled to renew those copyrights as well. 

The 1940 amendment to the Act removed the separate registration requirement, allowing individual authors to renew copyrights for periodical contributions without initial separate registration, but did not extinguish the publisher's renewal rights. Thus, SRF retains renewal rights for Yogananda's periodical articles if it can establish the informal assignment. The court reverses the district court's summary judgment on periodical articles and remands for factual determination regarding the assignment.

Regarding sound recordings of Yogananda's lectures, the 1909 Act does not apply, and any rights are governed by California common law copyright. California law protects common law copyrights in sound recordings, allowing for their transfer. Under California law, works created by employees in the scope of employment are owned by the employer unless otherwise agreed upon.

The district court correctly dismissed SRF's assertion that Yogananda's recorded works were created as works for hire or as part of a corporate entity. However, it incorrectly concluded that SRF did not present a triable issue regarding whether Yogananda assigned his common law copyrights to SRF, leading to a reversal on that point due to sufficient conflicting evidence regarding intent to transfer intellectual property rights.

Regarding photographs claimed by SRF, which were taken by various third parties and published in SRF's magazine, the court found that SRF failed to prove these were works for hire. Specifically, for four photographs with unknown authors, SRF could not demonstrate they were taken at SRF's instance or expense. The claim for a photograph by Arthur Say was also rejected due to lack of evidence that he was an SRF employee or that he intended to transfer copyright.

The court's grant of summary judgment for photographs taken by SRF employees Frederick and Durga Mata was based on the rejection of Ananda Mata’s declaration, which the court deemed insufficient. However, the appellate court found that the district court improperly assessed credibility at the summary judgment stage. Ananda Mata's declarations, which included her personal knowledge of the employees' roles and the circumstances under which the photographs were taken, constituted sufficient evidence to create a triable issue on whether these photographs were works for hire.

Consequently, the appellate court affirmed the district court’s summary judgment regarding the photographs by unknown authors and the photograph by Arthur Say, but reversed it concerning the photographs taken by Frederick and Durga Mata, remanding for further proceedings on the copyright infringement claims related to these works, along with certain books and articles. The ruling is partially affirmed and partially reversed, with each party bearing its own costs.