Aalmuhammed v. Lee
Court of Appeals for the Ninth Circuit
202 F.3d 1227 (9th Cir. 2000)
Spike Lee (defendant) produced the film Malcolm X. Jefri Aalmuhammed (plaintiff) assisted with the production-helping Denzel Washington with his role, directing him on set, suggesting script edits used in the final cut for historical and religious accuracy, and editing some footage-but Lee had the final say on everything Aalmuhammed contributed, and there was no written contract. Aalmuhammed was denied co-writer credit and listed instead as 'Islamic Technical Consultant.' He sued Lee, his production companies, and Warner Brothers for a declaration that the film was a joint work of which he was a co-author. The district court granted the defendants summary judgment, and he appealed.
Whether a valuable and independently copyrightable contribution to a work necessarily makes the contributor a joint author of that work.