How to Make an American Quilt

(1995)   Tags: Universal

Brown v. McCormick

This suit, alleging copyright infringement and related causes of action, arises out of a dispute over the use of plaintiff’s quilt block patterns during the filming and merchandising of the motion picture How to Make an American Quilt.  Plaintiff Brown was hired for $750 to design a quilt for the film “on condition that she would retain the copyright in all her designs.”  The designs were then used in numerous promotional tie ins to the movie without crediting Plaintiff and infringing her copyright.

Judgment: Defendants infringed Brown’s copyrighted designs. Further, Defendants should have obtained Brown’s authorization prior to displaying “The Life Before” for purposes not directly related to the Movie. Because Defendants’ actions did not constitute willful infringements, however, Brown’s award amount is limited to actual and statutory damages.