Manners v. Morosco

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Manners v. Morosco (1920) is a U.S. Supreme Court case about rights to a stage play and to film adaptations.

Two main holdings:
- The copyright transfer contract in this case was not limited to five years. It addressed minimum requirements, so the agreement could last longer than five years.
- Transferring the right to produce a stage play does not automatically grant the right to make a movie based on the play. However, when a contract grants exclusivity, it creates a negative obligation: the original creator is prevented from doing anything that would undermine that exclusivity, effectively forfeiting the creator’s own right to authorize a film adaptation.

The Court ordered both parties not to proceed with a film version.

Background:
- The case involved the play Peg o' My Heart by J. Hartley Manners.
- A 1919 film adaptation directed by William C. deMille and starring Wanda Hawley was made but never released due to issues raised in this case.
- Manners later produced a 1922 version starring Laurette Taylor, with a 1933 version following later.

Dissent:
- Justices John Hessin Clarke and Mahlon Pitney dissented, saying they saw nothing in the contract indicating an expectation of more than five years.