Supreme Court of the United States
Georgia, Petitioners v. Public.resource.org, Inc.
April 27, 2020590 U.S. 255
Summary
The Court held that annotations in Georgia's official annotated code are not eligible for copyright protection under the government edicts doctrine. The doctrine applies because the annotations were authored by an arm of the legislature in the course of its official legislative duties, regardless of whether the annotations themselves have the force of law. The Court therefore affirmed the judgment requiring the copyright claim to fail.
Holding
- Application of the government edicts doctrine to legislative annotations. The government edicts doctrine applies to works created by legislators, as well as judges, in the course of their official duties. Such officials cannot be treated as the authors of those works for copyright purposes.
- Status of the Code Revision Commission and its preparation of the annotations. The Code Revision Commission functioned as an arm or extension of the Georgia Legislature, and its preparation and supervision of the annotations occurred in the discharge of legislative duties.
- Whether the annotations' nonbinding status makes them copyrightable. The annotations' lack of legal force does not make them copyrightable. The government edicts doctrine turns on the identity and official capacity of the author, not on whether the material is binding law.
Docket 18-1150
Cited authorities
- CA11
- 17 U.S.C. § 106
- 17 U.S.C. § 302
- 17 U.S.C. § 102
- 17 U.S.C. § 201
- 17 U.S.C. § 101
- 17 U.S.C. §§ 102
- Ga. Code Ann. § 34-9-260