Procedural Posture

Appellant movie studio sought review of the decision of the Superior Court of Los Angeles County (California), which rendered judgment that appellant’s personal services contract with respondent actress was at an end because it had run for seven years, the maximum term allowed for such contracts pursuant to Cal. Labor Code § 2855 (formerly Cal. Civ. Code § 1980). The judgment also enjoined appellant from attempting to enforce the contract.

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Overview

Respondent actress sought a declaratory judgment that her contract to make movies for appellant movie studio was at an end because it had run for seven years from date of execution, the maximum term permitted pursuant to Cal. Labor Code § 2855 (formerly Cal. Civ. Code § 1980). Appellant argued that the limit referred to years of actual service and excluded periods of suspension provided for in the contract. The trial court rendered judgment for respondent and enjoined appellant from seeking enforcement. Appellant sought review. The court affirmed but struck the injunctive provision. The court rejected the argument that the legislature’s purpose in amending the provision that became Cal. Labor Code § 2855 was to except personal services contracts from the seven-year limit, holding that the amendment was made to clarify what had been redundant language, and that if the legislature had intended to do as appellant suggested, it would have used phrases that referred to “years of actual service,” which had not been done. The court struck the provision granting the injunction, finding that there was no evidence to suggest that appellant would attempt enforcement if not restrained.

Outcome

The court affirmed the holding that respondent actress’s contract with appellant movie studio terminated at the end of seven years, the maximum term permitted by law for personal services contracts, rejecting the idea that the limit referred to seven years of actual services rendered. The court struck the lower court’s grant of an injunction against appellant, holding there was no indication it intended to seek enforcement if not restrained.

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