Bob: I believe that the life plus 70 years rule as stipulated by the Berne Convention (then used outside the U.S.) presumes that the creator holds/held the copyright ownership. If the Jesuits originally held the copyright, then Browne's work would be considered a work for hire, I believe, and the expiration would be 75 years from publication or 100 years from creation, whichever comes first. If Browne assigned to the Jesuits the copyright upon his death, I don't know which term is used. I can ask my intellectual property professor. Btw, we in the colonies only came into 20th century copyright law in 1976, when Congress decided to adopt the Berne Convention rules used internationally.
Randy:
It is inaccurate,or at least misleading, to say that works published before 1923 fall into the public domain if their copyrights are not renewed. It's hard to read that web page and then read the case it relies on, Twin Books v. Walt Disney, and think the web author and the court are talking about the same case/rules of law. 1923 was only the date Bambi was produced in Germany without copyright notice, which Disney unsuccessfully tried to twist into its own public domain law--foreign copyright did not require copyright notice, only publication, and that did not make Bambi fair game for public domain in the U.S., much to Disney's regret. The actual date for public domain on non-renewed copyrights is 12/31/1963,based upon 1909 law modified in 1992, although renewal rights get complicated when the creator is dead. Assuming a live author or validly transferred rights at death, between 1/1/1964 and 12/31/1977, renewal is automatic, and after that, the 1976 law takes over, which uses a different basis to conform to the rest of the world. For the rudiments of U.S. copyright law, see U.S. Supreme Court case, Eldred v. Ashcroft, 123 S.Ct. 1505, (2003). But there are many permutations the case does not address. I have probably gone into much more detail than necessary here, but 1923 wasn't a red-letter date for anything, even Bambi, and I wouldn't rely on that web page for much, if anything. But each to his own.
