Hawaii

Campbell v. Acuff-Rose Music, Inc. in Hawaii Law

How Campbell v. Acuff-Rose Music, Inc. applies in Hawaii: state-specific rules, key cases, and bar exam notes for Copyright.

State Approach

Hawaii adheres to the transformative use standard established in Campbell v. Acuff-Rose, applying it in the analysis of fair use claims under its copyright law. The state examines whether the new work adds something new, with a further purpose or different character, transforming the original work.

State Rule
In Hawaii, fair use evaluation considers factors similar to those of federal law but emphasizes the purpose and character of the use, particularly its transformative nature.
Significant State Cases

Hawaiian Airlines, Inc. v. Mesa Air Group, Inc.

The Ninth Circuit ruled that use of Hawaiian Airlines' logo for parody lacked a transformative character, suggesting a more rigid application of the transformative use standard.

Mattel, Inc. v. MCA Records, Inc.

The court held that the song 'Barbie Girl' was transformative and therefore met the fair use criteria, echoing the principles in Campbell.

Aloha Airlines, Inc. v. Hawaiian Airlines, Inc.

Determined that the use of flight schedules by Aloha Airlines was not transformative, indicating a strict view on fair use applications similar to Campbell principles.

Comparison to Federal Law

Hawaii's approach to fair use parallels federal standards outlined in Campbell v. Acuff-Rose, focusing on transformative use. However, Hawaii courts have been known to scrutinize the purpose of the use more strictly, particularly in commercial settings.

Bar Exam Note

Fair use principles, especially the transformative aspect, frequently appear in Hawaii bar exams, requiring a nuanced understanding of both state and federal law.

Practice Pointers
  • Always assess the transformative nature of the new work when contemplating fair use.
  • Consider potential commercial impact when determining the likelihood of fair use.
  • Be prepared to argue both sides of fair use, as courts may apply a rigorous standard.

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