MGM paid for a novel. Joan Crawford completed the picture. Then two playwrights won a court order against its exhibition.

That compact sequence is the documented core of Letty Lynton, a 1932 film that survived physically while remaining outside ordinary authorized circulation for decades. The case was not about ownership of an old murder story, and it was not a claim that MGM had failed to license Marie Belloc Lowndes’s novel. It turned on protected dramatic expression from a different work, Dishonored Lady, and on three connected scenes the appeals court found in MGM’s film.

The legal record is unusually clear about the infringement and the profit accounting. It is less complete about every screening, print, and rights decision between 1936 and the film’s authorized return in 2026. That distinction is essential to telling the story accurately.

One historical case, two later works

In 1857, Madeleine Smith stood trial in Scotland in the poisoning death of her lover. The public record later supplied material to more than one author.

Edward Sheldon and Margaret Ayer Barnes wrote Dishonored Lady and registered it as an unpublished dramatic composition in 1930. Marie Belloc Lowndes separately drew on the same history for her novel Letty Lynton. The parties later agreed that Lowndes’s novel did not infringe the play, a point recorded in the 1934 federal trial ruling.

Historical facts were open to both writers. Sheldon and Barnes could still claim the original dramatic expression they added, including their selection and arrangement of incidents.

The deal MGM did not complete

MGM first negotiated for the motion-picture rights to Dishonored Lady. The sellers signed a conditional contract with a $30,000 price. It would take effect only if the Hays organization withdrew its objection to adapting the play. The objection remained, so the condition was never met.

The studio then bought a different property. On December 4, 1931, it paid $3,500 for the film rights to Lowndes’s novel. The trial opinion and the later Second Circuit opinion document that sequence.

This was not a ban by the Hays organization on the completed picture. The objection explains why MGM’s proposed play deal failed. MGM could and did proceed with the novel it had licensed.

A finished Crawford film

MGM produced Letty Lynton in early 1932 and released it that year with Crawford in the title role. Sources differ on the precise release event, so the year is the safest uncontested statement. The AFI Catalog records the production and release history.

Sheldon and Barnes challenged expression they said the film had taken from their play. Their argument did not depend on treating Lowndes’s novel as infringing.

MGM wins, then loses

On July 25, 1934, the federal trial judge dismissed the playwrights’ complaint. He found no substantial copying of the protected material they had added to the public-domain story.

The playwrights appealed. In January 1936, the Second Circuit reversed. Its opinion focused on three scenes in sequence: a former lover’s threat, his death by poisoning, and an examination by a district attorney that ends with an unexpected alibi.

The court compared what happened inside those scenes, not simply a generic order of threat, death, and questioning. It identified connected details in the home encounter, the location of the poison, and the heroine’s conversation with her new love. Those details had no counterpart in the historical story or Lowndes’s novel, the court found. They came from the playwrights’ dramatic invention.

MGM had licensed one source. Its picture nevertheless used protected expression from another.

An injunction against exhibition

The Second Circuit directed an injunction against the picture, together with damages and an accounting. On remand, the district court entered an interlocutory decree ordering the MGM companies not to exhibit Letty Lynton. The decree also required an accounting of gains and profits from making, distributing, licensing, and showing it. The order is recounted in the 1938 district-court opinion.

The consequence ran in two directions. MGM faced payment for past use of the playwrights’ work and an order against future exhibition. For audiences, a completed performance could remain preserved while dropping out of authorized general circulation.

A separate exhibitor received different treatment. A New York theatre had returned its print before the lawsuit. In 1938, the appeals court vacated that theatre’s injunction because another infringement was not reasonably expected. The Moredall opinion proves what happened to that print. It does not establish when every other copy left circulation.

How much of the profit belonged to the writers?

A court-appointed special master calculated about $588,000 in net profits. After disputes over deductions, the Second Circuit assigned Sheldon and Barnes one-fifth of the final net-profit base as restated on appeal. The calculations and adjustment appear in the district-court accounting opinion and the 1939 appellate opinion.

The infringement ruling had already been left standing. When the case reached the Supreme Court in 1940, the issue was profit apportionment, not a fresh decision on whether the three scenes infringed. The Court affirmed the one-fifth share.

Its reasoning was practical. The accounting was meant to capture profit attributable to the infringement and prevent unjust enrichment, not to punish MGM by transferring the profit generated by the rest of the picture. The final post-remand dollar award has not been verified against a complete primary decree, so one-fifth is the supported formulation.

Preserved does not mean authorized

Warner Bros. Discovery later described Letty Lynton as unseen publicly since 1936 and unavailable for nearly ninety years. Its restoration announcement is authoritative for what Warner announced, but not an independent history of every screening.

Unauthorized bootleg copies circulated. No exhaustive record of screenings, broadcasts, and archive loans from 1936 through 2025 has been located. The evidence supports a narrower conclusion: the film survived but remained outside ordinary authorized circulation. Finding a copy was not the same as a studio being able to exhibit, license, or sell the film.

Two copyrights, then a return

The copyright in Dishonored Lady was renewed in 1957. Applying the United States Copyright Office’s term guidance, its term ran through December 31, 2025. The play entered the United States public domain on January 1, 2026.

The film has a separate copyright record. The 1959 renewal catalog reports that Loew’s, Inc. renewed Letty Lynton. On the face of that record and the Copyright Office’s ninety-five-year rule, the film’s separate United States copyright runs through 2027. The play is public domain in the United States. The film is not.

Film historians and contemporary reporting connect the play’s expiration to the movie’s return. Warner’s complete clearance file and the complete final decree have not been obtained, so the evidence does not prove that expiration was the only condition.

The timing is documented. The restoration screened at the TCM Classic Film Festival on May 1, 2026. Criterion’s festival coverage supports the date, and IndieWire later reported the festival premiere and commercial Blu-ray availability by July 28.

A rights decision MGM made in 1931 led to a finding that three scenes contained dramatic expression belonging to two playwrights. The remedy reached a complete Joan Crawford film. The work remained, and authorized audiences could see it again in 2026.

Evidence limits

This account does not claim a literal absence of every viewing or print after 1936. It does not claim that the play’s term expiration was the sole cause of the return. It does not treat the film as public domain. The complete final post-remand decree, Warner’s clearance file, a complete 1936 to 2025 exhibition history, and the chain of title behind the film’s renewal have not all been recovered.

Selected sources

Corrections

Hollywood Case File separates documented claims from reported context. If you have a primary record that changes or clarifies this account, use the site’s corrections and contact route. A published correction should identify what changed, why it changed, the date, and the supporting evidence.