A. A. Hoehling v. Universal City Studios, Inc.

A.A. Hoehling (plaintiff) wrote a factual book about the Hindenburg disaster, advancing the theory that a crew member named Eric Spehl sabotaged the airship, motivated by his anti-Nazi communist love interest; Hoehling reached that conclusion from contemporaneous accounts, interviews, and his own reasoning. A decade later, Universal City Studios (defendant) made a film with a subplot depicting a Spehl-like saboteur (renamed Boeth) acting for the same reasons. Hoehling sued for copyright infringement. The district court granted the defendants summary judgment, and Hoehling appealed.

Whether historical facts, discoveries, and insights are eligible for copyright protection.