Aalmuhammed v. Lee

Court of Appeals for the Ninth Circuit

202 F.3d 1227 (9th Cir. 2000)

With regard to joint works, a valuable and copyrightable contribution to a work does not necessarily constitute authorship.

Relevant Facts

Spike Lee (the defendant) produced the movie Malcolm X, which starred Denzel Washington. Jefri Aalmuhammed (the plaintiff) assisted with production of the movie. The plaintiff helped Washington with his role, directed him on set, suggested script edits that were used in the final cut to ensure historical and religious accuracy, and edited some of the movie in post-production. The defendant, however, had the final say on all of the plaintiff’s contributions. There was no written contract between the parties. Later, the plaintiff requested but was denied credit as a cowriter of the movie. Instead, the defendant included the plaintiff in the credits as “Islamic Technical Consultant.” Subsequently, the plaintiff brought suit against the defendant, his production companies, and Warner Brothers, seeking a declaratory judgment that the movie was a joint work, and that the plaintiff was a coauthor. The district court granted the defendant summary judgment, and the plaintiff appealed.

Issue

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Holding & Reasoning

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Concurrence

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Dissent

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Last updated:

December 2, 2020

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Procedural History

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Citations

202 F.3d 1227 (9th Cir. 2000)