Erikson v. Trinity Theatre, Inc.

Karen Erickson (plaintiff), a Trinity Theatre (defendant) co-founder, wrote Prairie Voices and Much Ado About Shakespeare largely before consulting Trinity's actors in improvisational sessions, retaining final control over what material was incorporated, and separately wrote Time Machine, initially crediting collaborator Paddy Lynn as co-author and paying him royalties, though Erickson later denied intending joint authorship. After Trinity stopped paying Erickson royalties under their 1988 agreement and refused to stop performing the plays once she obtained copyright registrations, she sued for infringement and won an injunction, which Trinity appealed, claiming joint authorship in all three plays based on its actors' creative input.