Documentary filmmakers who use unlicensed video clips can breathe a little easier, after an appellate panel reversed itself Thursday in a closely watched copyright case involving Netflix ‘s “ Tiger King ” series. A three-judge panel of the 10th Circuit Court of Appeals ruled that the filmmakers’ use of a 66-second clip from a character’s funeral was sufficiently transformative to qualify for “fair use” protection. The court thus upheld a lower court decision throwing out a videographer’s lawsuit against Netflix and the filmmakers. The same panel reached the opposite conclusion two years ago, raising alarms in the documentary community. Documentarians often rely on archival footage, and they usually obtain permission from copyright holders to include it in their films. But sometimes they cannot reach a deal to license the footage, or cannot find whoever shot it, leading them to claim “fair use.” In this case, videographer Tim Sepi sued, accusing Netflix of taking his footage without compensation.…