Welch v. Mr. Christmas Inc.
The case concerns a professional actor (plaintiff) suing a manufacturer of artificial Christmas trees (defendant) under New York Civil Rights Law § 51 for unauthorized use of a television commercial. The defendant continued airing the commercial in 1975 after the original contract and option period had expired, despite warnings. A jury awarded both compensatory and exemplary damages. The Court of Appeals affirmed the lower court's decision, clarifying that knowledge is not required for compensatory damages under § 51, and that for exemplary damages, "knowing use" without consent is sufficient, not requiring malice or recklessness. The court also held the defendant responsible for the distributor's unauthorized use and the principle of expired consent.