Friday, December 6, 2013

Jacobs v. CBS Broadcasting case brief

Jacobs v. CBS Broadcasting case brief summary
291 F.3d 1173 (2002)

Plaintiffs, optionees of a proposed television program, appealed from an order of the United States District Court for the Central District of California that granted summary judgment in favor of defendant network on the ground that an earlier, nonjudicial proceeding collaterally estopped the optionees from bringing their claim to court.

A writer developed a script for a program called "Final Edition," and the optionees sought to secure a television broadcast commitment from a network. The network acquired the broadcast rights to the show, and agreed to give the optionees credit as co-producers if a show was developed based on the property. Ultimately defendant network developed a series based on the same premises, called "Early Edition," but at the tentative credit stage failed to give the writer credit as a participating writer. The writer sought review by the Writers Guild of America (WGA), which denied him relief. The optionees subsequently sued to enforce their agreement with the network. The district court ruled that the optionees were collaterally precluded from raising the issue of credit that had been decided in the WGA proceeding, although they had not been parties to that action.

The court of appeals reversed, finding there were insufficient procedural safeguards and formalities in the WGA proceeding to bind the non-participating parties.

The judgment of the district court was reversed because the nonjudicial proceeding was too informal and lacked the requisite procedural safeguards to have preclusive effect.

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