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Miller v. Universal City Studios, Inc.

650 F.2d 1365 (1981)

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Miller v. Universal City Studios, Inc.

United States Court of Appeals for the Fifth Circuit

650 F.2d 1365 (1981)

Facts

A girl was kidnapped and buried underground for several days until she was rescued. Gene Miller (plaintiff), a reporter, worked with the victim to write a book about the kidnapping. The book contained Miller’s research about the facts of the crime, and Miller spent substantial effort and resources to discover the facts. Universal City Studios, Inc. (Universal) (defendant) made a movie based on the research contained within Miller’s book without obtaining movie rights to the book. Miller sued Universal in federal district court for copyright infringement. Universal argued that Miller’s book contained only uncopyrightable facts. The district court instructed the jury that although facts were uncopyrightable, an author’s research of facts was copyrightable. The district court permitted the jury instruction to support a policy of encouraging reporters to spend time and money researching facts because the research would ultimately be copyrightable. The jury held in Miller’s favor, and Universal appealed.

Rule of Law

Issue

Holding and Reasoning (Roney, J.)

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