MINOR MIRACLE PRODUCTIONS, LLC v. Starkey
271 P.3d 1189
Idaho2012Background
- MMP, an Idaho LLC, produced the film The Hayfield with Richards funding and Starkey writing/directing.
- An operating agreement was allegedly formed but Starkey never signed it.
- Starkey allegedly attempted to sell interests and encumbered film assets without Richards' knowledge.
- Starkey unilaterally copyrighted the screenplay and the film's website.
- MMP and Richards sued Starkey for breach of fiduciary duty, breach of contract, and conversion; Starkey later failed to comply with discovery orders.
- The district court sanctioned Starkey, struck defenses, granted judgment on the pleadings in favor of MMP/Richards, and awarded costs and fees.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the district court had subject matter jurisdiction | Starkey argues federal copyright jurisdiction. | Starkey contends 28 U.S.C. § 1338 applies. | District court had jurisdiction; claim did not arise under federal copyright law. |
| Whether a district judge's failure to recuse is reviewable without a motion | Starkey argues recusal was reversible error. | Recusal issue requires a motion and record. | Not reviewable without a motion for disqualification. |
| Whether remaining issues are properly before the Court | Starkey raises numerous unsupported issues. | Issues are waived for lack of argument/authority. | All issues waived except jurisdictional challenge. |
| Whether MMP is entitled to attorney fees on appeal | N/A (MMP seeks fees based on prevailing status). | N/A (not opposed in issue framing here). | MMP/Richards entitled to attorney fees on appeal; costs awarded. |
Key Cases Cited
- Arthur Young & Co. v. City of Richmond, 895 F.2d 967 (4th Cir. 1990) (ownership questions may fall under state law; not necessarily arising under federal copyright law)
- United States v. Cotton, 535 U.S. 625 (S. Ct. 2002) (sovereign power to hear; subject-matter jurisdiction cannot be forfeited)
- Bach v. Bagley, 148 Idaho 784 (2010) (waiver of arguments for lack of particularity and authority; appellate standard)
- Idaho Dept. of Health & Welfare v. Doe, 150 Idaho 563 (2011) (recusal and discretionary rulings require trial-court objection; reviewed for abuse of discretion)