Hawaii

Arnstein v. Porter in Hawaii Law

How Arnstein v. Porter applies in Hawaii: state-specific rules, key cases, and bar exam notes for Copyright.

State Approach

Hawaii follows the principles established in Arnstein v. Porter, applying a similar test to assess copyright infringement based on originality and substantial similarity. The courts recognize the importance of both qualitative and quantitative aspects of the similarities between works.

State Rule
In Hawaii, a work can be considered infringing if it is substantially similar to a protected work, evaluated through the lens of an ordinary observer's perspective.
Significant State Cases

Hawaiian Airlines, Inc. v. Norris

The Court held that the elements of originality and substantial similarity must be evaluated to determine copyright infringement, referencing principles consistent with Arnstein.

Bresnick v. Braun

This case analyzed the application of copyright law in light of Arnstein’s substantial similarity test, concluding that the defendant’s work did not sufficiently overlap with the plaintiff's protected elements.

Ono v. Hawaii State Legislature

The court ruled that the plaintiff must establish originality and demonstrate how the contested work used protected materials, mirroring the Arnstein standard.

Comparison to Federal Law

Hawaii's copyright infringement standard mirrors federal law under the Copyright Act, particularly the substantial similarity test. However, state courts may emphasize contextual factors more deeply pertinent to local culture or artistic expression.

Bar Exam Note

Questions on copyright issues similar to Arnstein v. Porter may appear on the Hawaii bar exam, focusing on the originality and substantial similarity doctrines.

Practice Pointers
  • Always assess both quantitative and qualitative elements when analyzing substantial similarity in copyright cases.
  • Review local case law to understand how Hawaii courts may interpret copyright claims differently than federal courts.
  • Be prepared to articulate the differences between protected and non-protected elements of a work when assessing infringement.

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