USCA Eleventh Circuit, February 25, 2008
In this copyright infringement action, the Eleventh Circuit Court of Appeals held that the “one-satisfaction rule” – a tort doctrine barring multiple recoveries for a single injury – applies to claims brought under the Copyright Act. Plaintiff BUC International Corp. had brought claims arising out of the defendants’ use of BUC’s “Used Boat Price Guide.” Prior to trial, BUC settled with three of the six original defendants for a total of $790,000. At trial, the jury found the remaining, non-settling defendants liable for copyright infringement and awarded BUC $1.6 million in actual damages.
The non-settling defendants, after learning of the existence and amount of the prior settlement, moved pursuant to Fed. R. Civ. P. 60(b)(5) for partial relief from judgment on the basis of the one-satisfaction rule, which provides that “a plaintiff is entitled to only one satisfaction for a single injury, such that the amounts received in settlement from an alleged tortfeasor are credited against judgments for the same injury against non-settling tortfeasors.” The district court denied the motion, analogizing the attempt to claim credit under this rule to a claim for contribution, which, under federal precedent, would only exist “if Congress created such a right, expressly or impliedly, or the courts created such a right as a matter of federal common law.” The district court concluded that no such right exists under the Copyright Act.
The Eleventh Circuit reversed, distinguishing the concept of contribution from the one-satisfaction rule. While contribution is a cause of action between joint tortfeasors, “[t]he one-satisfaction rule, by contrast, operates to prevent double recovery, or the overcompensation of a plaintiff for a single injury . . . . It is not a right created to protect defendants, but to limit plaintiffs.” Thus, the court held that there was no basis for withholding application of the rule to BUC’s recovery, given that “the claims settled by BUC prior to trial are for precisely the same injury accounted for by the jury’s verdict and award.” Noting that some courts grant dollar-for-dollar reductions, while others have reduced judgments by the proportionate share of the settling defendants’ liability, the court applied a dollar-for-dollar reduction without analysis, because the defendants requested a dollar-for-dollar reduction without objection from BUC. The court thus reduced BUC’s $1.6 million award by the $790,000 settlement amount.