In the Manners v. Morosco case of 1919, playwright Rachel Crothers sued Charles Frohman Inc., and William A. Brady for copyright infringement after they produced a play that she claimed was based on her work "A Man's World". The defendants argued that their play, "The Misleading Lady", did not infringe upon Crothers' rights because it was an original creation. However, the Supreme Court ruled in favor of Crothers stating that even though there were differences between the two plays, there were enough similarities to constitute copyright infringement. This ruling established important precedent regarding intellectual property rights and set a standard for determining what constitutes as plagiarism in creative works.

In the dissenting opinion for Manners v. Morosco, Justice Holmes argued that the plaintiff's rights were not adequately protected by the majority ruling. He believed that a playwright should have control over their work and its use in other media forms, such as film adaptations. In this case, he felt that Mrs. Manners had not given explicit consent to Mr. Morosco to adapt her play into a movie and therefore it was an infringement on her copyright protections under law. Holmes asserted that while she did sell him some rights to her play "Peg O' My Heart", those rights did not extend beyond stage performances without clear agreement from both parties involved.