law of any particular state, in order to create a uniform, nationwide law. The Court listed 11 factors in determining whether someone is an independent contractor or an employee. In determining whether a hired party is an employee under the general common law of agency, we consider the hiring party's right to control the manner and means by which the product is accomplished. Among the other factors relevant to this inquiry are [1] the skill required; [2] the source of the instrumentalities and tools; [3] the location of the work; [4] the duration of the relationship between the parties; [5] whether the hiring party has the right to assign additional projects to the hired party; [6] the extent of the hired party's discretion over when and how long to work; [7] the method of payment; [8] the hired party's role in hiring and paying assistants; whether the work is part of the regular business of the hiring party; [9] whether the hiring party is in business; [10] the provision of employee benefits; [11] and the tax treatment of the hired party. Based on these factors, the Court held Reid was an independent contractor. Reid supplied his own tools, was without any extensive supervision and was free in the way he met his deadlines. CCNV could not assign more projects to Reid, and paid him in the normal manner independent contractors are done. The case was remanded to determine whether CCNV could still be regarded as a joint author of the sculpture and co-owner of the copyright, if the District Court determined that the parties intended their contributions be merged into a unitary whole. Significance While the case was pending on remand, Mitch Snyder of CCNV died. The parties subsequently filed a “Joint Motion for Entry of Consent Judgment.” The consent judgment has the following terms: Reid was the author of Third World America and solely owned the copyrights to three-dimensional copies of the work, but Reid agreed to certain restrictions on how three-dimensional copies presented the work. CCNV solely owned the physical copy of the sculpture. CCNV and Reid were co-owners of two-dimensional copies of the work. The consent specified certain restrictions on how both parties could authorize displays of the two-dimensional copies. Community for Creative Non-Violence v. Reid, 1991 WL 415523 (D.D.C. 1991). In Nationwide Mut. Ins. Co. v. Darden (1992), Justice David Souter used the Court's understanding of