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Aalmuhammed v. Lee

United States Court of Appeals for the Ninth Circuit
202 F.3d 1227 (9th Cir. 2000)


Facts

Spike Lee (defendant) co-wrote, directed, and co-produced the movie Malcolm X, which starred Denzel Washington. Jefri Aalmuhammed (plaintiff) knew a great deal about Malcolm X’s life and the religion of Islam, which played an important role in the movie. Under the supervision of Lee, Aalmuhammed assisted with production of the movie, including helping Washington with his role, directing Washington on set, suggesting script edits that were used in the final cut, ensuring historical and religious accuracy, and editing some of the movie in post-production. Lee had the final say on all of Aalmuhammed’s contributions. Aalmuhammed did not have a written contract with Lee or Warner Brothers. Aalmuhammed requested but was denied credit as a cowriter of the movie. Instead, Aalmuhammed was in the credits as “Islamic Technical Consultant.” Aalmuhammed brought suit against Lee, his production companies, and Warner Brothers, seeking a declaratory ruling that Malcolm X was a joint work, and that Aalmuhammed was a coauthor. The district court granted Lee summary judgment. Aalmuhammed appealed.

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Holding and Reasoning (Kleinfeld, J.)

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