Community for Creative Non-violence v. Reid

The Community for Creative Non-violence (CCNV) (plaintiff) commissioned sculptor Reid (defendant) to create a homelessness-themed statue, providing input on the design and periodically checking on progress, but Reid worked in his own studio on his own schedule, hired and paid his own assistants, was paid a flat fee upon completion, and received no employee benefits or tax withholding. When Reid refused to return the statue over concerns about its durability for a planned tour, CCNV sued to recover it and resolve copyright ownership; the district court found it was a work made for hire owned by CCNV, and the D.C. Circuit reversed.