The Eleventh Circuit ruled Thursday that it lacked jurisdiction to consider Venezuela's LaTele Television's appeal of a sanctions order for attorneys' fees in a copyright dispute with Telemundo, finding the sanctions are intertwined with the underlying case's merits and cannot be separately considered on appeal.
The sanctions order, which requires LaTele Televsion CA to pay $513,000 in attorneys' fees, was imposed by a Florida district court in a copyright suit that LaTele filed in 2012 against Florida-based Telemundo Communications Group LLC alleging the Spanish-language network's telenovela “El Rostro” shares the same author, core plot, exposition, conflict, climax and closer as LaTele’s program “Maria Maria.”
Telemundo had pushed the Eleventh Circuit to dismiss the appeal for lack of jurisdiction, arguing that the appeal of the sanctions order would be “inextricably intertwined” with the merits of the underlying case.
In reviewing its jurisdiction, the Eleventh Circuit found that the sanctions order at issue “obviously did not 'end the litigation on the merits' because it addressed only the narrow issue of attorneys' fees for plaintiff's discovery violations,” but it reviewed LaTele's argument under the collateral order doctrine, which allows appellate courts to exercise jurisdiction over a “small class” of nonfinal rulings.