Goldstein v. California

Summary

The U.S. Supreme Court reviewed the constitutionality of California Penal Code § 653h, which criminalized unauthorized duplication and sale of sound recordings. The Court held that the Copyright Clause did not exclusively reserve copyright protection to the Federal Government and that California had not relinquished its authority to protect recordings under state law. The Court also rejected the argument that the state statute was preempted by federal copyright law as it existed before Congress extended federal protection to certain sound recordings.

Holdings

1. The Copyright Clause did not relinquish all state power to grant copyright-like protection, and California retained authority to protect sound recordings that Congress had not brought within the federal copyright scheme.
2. California Penal Code § 653h was not invalid merely because the protection it provided for copied sound recordings was unlimited in duration.
3. Section 653h was not preempted by the federal copyright statutes as applied to sound recordings fixed before February 15, 1972.

Questions Presented

1. Whether the Copyright Clause of the Constitution implicitly vested exclusive authority in Congress and therefore barred California from protecting sound recordings through state law.
2. Whether California Penal Code § 653h was unconstitutional because it created copyright protection of unlimited duration.
3. Whether § 653h was preempted by the federal copyright statutes or conflicted with federal copyright policy under the Supremacy Clause.
4. Whether the 1971 federal amendment extending copyright protection to sound recordings applied to recordings fixed before February 15, 1972.

Disposition

affirmed