A US appeals court has affirmed a jury verdict in favour of Apple and director M. Night Shyamalan, concluding a long-running legal dispute over the psychological television series Servant. The Ninth Circuit Court of Appeals on Thursday turned down a challenge brought by filmmaker Francesca Gregorini, who had claimed that the Apple TV+ production copied her feature film, The Truth About Emanuel. The appellate bench left intact a finding reached by a California jury last year that had cleared the defendants of copyright infringement. The television show, which aired on Apple’s streaming platform between 2018 and 2023, shared core narrative concepts with Gregorini’s earlier cinematic work, but the judicial panel determined that the trial verdict was legally sound and should not be overturned.
Claims of Imitation Over Shared Narrative Premise
Gregorini initiated legal action against Apple and Shyamalan in 2020, asserting that the television series had made unauthorised use of significant elements from her independent release. Her motion argued that the series was a brazen copy, pointing specifically to structural similarities concerning a grieving mother who develops a deep psychological bond with a lifelike doll after the death of her newborn baby. Gregorini maintained that the parallels between the narratives extended well beyond standard creative tropes. However, defence counsel contended successfully that common concepts cannot form the basis of a copyright violation and that the development of the television show proceeded independently.
Multi-Year Litigation Traversed Reversal and Trial
The legal contest progressed through several contentious stages before reaching its appellate conclusion. A federal trial judge had initially dismissed the action, but the Ninth Circuit revived the lawsuit in 2022 on the grounds that the initial dismissal was premature, thereby returning the matter for formal trial proceedings. The dispute was subsequently presented before a California jury last year. Jurors evaluated the evidence and ruled against Gregorini, concluding that the plaintiff failed to establish that the creative personnel behind Servant had ever viewed or accessed her film prior to making the series. Gregorini promptly appealed that trial determination, requesting the circuit court to set aside the findings.
Crucial Threshold of Proof Regarding Creative Access
In upholding the jury’s decision, the Ninth Circuit underscored the central role that demonstrable access plays in resolving creative ownership battles. Copyright doctrine requires a claimant to demonstrate that alleged infringers had reasonable access to the protected original material to prove that similarities did not arise from coincidental creation. The appeals panel reaffirmed that standard themes involving maternal loss, human bereavement, and attachment to artificial infants belong in the realm of unprotected ideas rather than protected expression. Because the trial record lacked sufficient proof that the creators of Servant had accessed the earlier independent film, the appeals court ruled that the jury’s verdict must stand, bringing substantial finality to the multi-year infringement suit.
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