Happy Groundhog Day! In 1995, the movie Groundhog Day became the subject of a copyright infringement suit. In Arden v. Columbia Pictures Indus., Inc., 908 F.Supp. 1248 (S.D.N.Y.1995), a federal court granted summary judgment in a case alleging that the film Groundhog Day, depicting a man living the same day repeatedly, infringed copyright of a novel featuring the same situation, because repetition is necessary element of the idea of a repeating day and therefore considered a scene a faire. Scenes a faire are those elements of a work that necessarily result from the choice of a setting or situation or sequences of events which necessarily follow from a common theme and receive no copyright protection.
The court held that the novel One Fine Day, which told the story of a man trapped in a repeating day, forced to live the same day over and over, was not substantially similar to the movie Groundhog Day, also featuring a man caught in a repeating day. Although the novel and film were based on same idea, the mood of the novel was dark and introspective, while the film was essentially a romantic comedy, and any similarities between the two related only to ideas, concepts or abstractions that are not protected under copyright law.
Click here to read the full text of the opinion in Arden v. Columbia Pictures.