In the 1992 case of Jeffery Antoine v. Byers & Anderson, Inc., et al., the U.S Supreme Court addressed a dispute over copyright infringement. The plaintiff, Jeffery Antoine, alleged that Byers & Anderson had copied his computer program and used it in their own software without permission or compensation. However, the court ruled against him on several grounds: first, because he did not register his work with the Copyright Office before filing suit; secondly because he failed to prove that there was substantial similarity between his original work and defendant's product; thirdly because some parts of a computer program (like its functional elements) are not protected by copyright law as they constitute ideas rather than expression. Therefore, even if these were copied by defendants it would not amount to infringement under US Copyright Act.

In the dissenting opinion for Jeffery Antoine v. Byers & Anderson, Inc., et al., 1992, it was argued that the majority's decision to dismiss Antoine’s claim under Section 1983 of the Civil Rights Act was incorrect. The dissenting justices believed that court reporters should not be granted absolute immunity from such claims because they are not judicial officers and their duties do not involve discretionary judgment or decision-making related to judicial proceedings. They contended that a court reporter merely transcribes what occurs in court and does not play an integral role in deciding cases or shaping outcomes. Therefore, granting them absolute immunity could potentially shield misconduct without any valid justification rooted in common law history or public policy considerations.