The Community for Creative Non-Violence, a homeless charity, paid a sculptor called James Earl Reid for a statue that depicted the plight of homeless people for a Christmas pageant in Washington DC, called "Third World America".
The District Court held that CCNV had the copyright, as it was a 'work made for hire' under the Copyright Act of 1976, 17 U.S.C. § 101, owned exclusively by CCNV under § 201(b).