Alexis Campbell

Yesterday, the U.S. Supreme Court affirmed the U.S. Court of Appeals for the Eleventh Circuit’s decision that a state code revision commission cannot claim copyright protection over annotated state code in Georgia et al. v. Public.Resource.Org., Inc. The Court dove into the judicially created “edicts doctrine,” which has not really been explored since the 1800s. The “original works” in question were supplementary annotations accompanying the statutes in Georgia’s Official Code, known as the Official Code of Georgia Annotated (“OCGA”). These annotations and summaries of judicial decisions were owned by Georgia’s Code Revision Commission (“Commission”), although they were originally authored by a division of the LexisNexis Group under a “work made for hire” contract.