Nash v. CBS, Inc.
United States Court of Appeals for the Seventh Circuit
899 F.2d 1537 (1990)
Jay Nash (plaintiff) wrote four nonfiction books theorizing that gangster John Dillinger's body double, not Dillinger himself, was killed by the FBI in 1934, and that Dillinger secretly relocated to San Diego and lived incognito to old age; CBS (defendant) aired a Simon and Simon episode incorporating many of Nash's theories, including Dillinger's supposed San Diego relocation, but never used any actual words or sentences from Nash's books. Nash sued for copyright infringement, and the district court granted CBS summary judgment, holding Nash's copyright covered only his presentation and exposition of historical events, not the underlying events or theories themselves.
Whether copyright law protects the expression of ideas of facts, but not the underlying ideas or facts themselves.