The Community for Creative Non-Violence (CCNV) v. Reid case in 1988 revolved around the issue of copyright ownership between an artist and a non-profit organization. The CCNV commissioned James Earl Reid to create a statue for a Christmas display, but disputes arose over the final product's design and location. When CCNV made alterations to the sculpture without Reid's permission, he filed suit claiming violation of his rights under the Copyright Act of 1976. The Supreme Court ruled in favor of Reid, stating that despite being commissioned by CCNV, he was not an employee but rather an independent contractor; therefore, he retained copyright ownership as per Section 101 of the Copyright Act which states that works created by independent contractors are owned by them unless there is a written agreement otherwise. This ruling clarified how "work-for-hire" applies within U.S copyright law.

In the dissenting opinion for Community for Creative Non-Violence et al. v. Reid, Justice Blackmun argued that the majority's interpretation of "employee" under Section 101 of the Copyright Act was too narrow and inconsistent with Congress' intent to broadly protect copyright owners' rights. He contended that an individual who creates a work at someone else’s request and hands over his or her rights in exchange for payment should be considered an employee under this law, regardless of whether they meet traditional employment criteria such as control by employer or provision of benefits. The dissent also criticized the majority's reliance on agency law principles instead of focusing on copyright-specific considerations like creative control and risk-taking which are more relevant to determining authorship in artistic works.