or non-lawmaking officials. This is elucidated by distinguishing the decision in Banks from Callaghan v. Myers where the Court permitted a reporter to hold copyright in explanatory materials he had added to the judgements, such as headnotes, syllabi, tables of contents, on the grounds that he did not have authority to speak with the force of law. The Court also rejected the contention that the US Copyright Statute while excluding “work[s] prepared by an officer or employee of the United States Government as part of that person’s official duties” from copyright protection, does not establish a similar rule for the States. The Court held that the policy reasons that justify the Federal Government’s decision to forfeit copyright protection for its own proprietary works, does not suggest an intent to displace the already narrow government edicts doctrine with respect to the States. The doctrine does not apply to non-lawmaking officials, leaving States free to assert copyright in the vast majority of expressive works they produce, such as those created by their universities, libraries, tourism offices, and so on. The State of Georgia also contended on policy grounds that the purpose of the Copyright Act is to promote the creation and dissemination of creative works and without such protection many states will be unable induce private parties to assist in the preparation of affordable annotated codes for widespread distribution. The Court however states that it cannot decide this matter and that the Congress is the right body to decide such a policy issue. Additionally, contrary to the Justice Thomas' dissent and State of Georgia's contention that the government edicts doctrine lacks textual footing, the Court stated that the doctrine has textual footing by way of the "authorship" requirement. The Court finally observes that a decision allowing copyright protection for anything merely falling short of being classified as a statute or a judicial opinion would result in First Amendment concerns. Dissenting opinions Justice Thomas joined by Justice Alito and Justice Breyer Justice Thomas holds that regulations cannot be copyrighted, but accompanying notes lacking legal force can be. The opinion states that the majority opinion was flawed on the following precedential and textual grounds. Precedential Grounds The opinion states that the majority incorrectly interpreted precedents and that they did not attempt to examine the root and context of the precedents. The opinion notes that while precedents establish that judicial opinion cannot be copyrighted, they