In Lil' Joe Records v. Wong Won (11th Cir. 2026), the court held that a 2 Live Crew member's copyright termination interest fell into his Chapter 7 bankruptcy estate, leaving the group one author short of the majority needed to reclaim five albums.
The en banc Ninth Circuit rejected an actress's claim to copyright in her brief filmed performance, holding that an individual acting contribution does not create a separately ownable work.
The Ninth Circuit denied joint-authorship status to a key creative consultant on 'Malcolm X,' holding that significant contribution is not enough without control and a shared intent to be co-authors.
The Supreme Court's unanimous 1989 ruling rejected control-based shortcuts and held that common-law agency principles decide whether a creator is an employee or an independent contractor for work-made-for-hire purposes.
