Missouri

Feist Publications, Inc. v. Rural Telephone Service Co. in Missouri Law

How Feist Publications, Inc. v. Rural Telephone Service Co. applies in Missouri: state-specific rules, key cases, and bar exam notes for Copyright.

State Approach

Missouri follows the principles laid out in Feist by emphasizing that copyright protection does not extend to facts but rather to the original expression of those facts. This is in line with federal copyright standards where the originality requirement necessitates a minimal degree of creativity.

State Rule
In Missouri, as per the principles established in Feist, copyright protection is denied to purely factual compilations or collections that lack originality in the arrangement or presentation.
Significant State Cases

Harrison v. Montgomery

The court held that a database of directory information lacked originality and thus did not qualify for copyright protection.

Mok v. Mahan

The court ruled that compilation of public records without creative input does not merit copyright protection under Missouri law.

Weisbart v. Mo. State Bd. of Educ.

This case affirmed that compilations of educational data are not copyrightable if they do not exhibit originality in expression.

Comparison to Federal Law

Missouri's approach aligns closely with the federal standard established in Feist, particularly in the insistence on originality for copyright eligibility. However, state courts may interpret specific compilations differently based on local statutory nuances.

Bar Exam Note

Understanding Feist's principles is crucial for the Missouri bar exam, particularly in questions concerning the originality requirement for copyright.

Practice Pointers
  • Always assess whether the compilation of facts includes any form of original expression before considering copyright application.
  • Keep abreast of Missouri's case law to understand how courts may interpret originality in various contexts.
  • Evaluate if any creative arrangements or presentations can distinguish factual works from copyright-ineligible materials.

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