Heine v. Appleton
Heine v. Appleton was the first court case that further established the limits of how and when the works of employees of the US Federal government are protected by copyright. Heine was a junior officer on Admiral Parry's expedition to Japan. His primary duty was to prepare sketches of the places the expedition visited.
According to John Tresansky, in the Catholic Law Review, "It was understood from the outset that all such works would be the exclusive property of the government." His drawings were published in the expedition's official report. Nevertheless Heine published the drawings, privately.
COPYRIGHT IN GOVERNMENT EMPLOYEE AUTHORED WORKS
- John 0. Tresansky (1981). "Copyright in Government employee authored works". Catholic University Law Review: p. 612. https://apps.dtic.mil/dtic/tr/fulltext/u2/a392914.pdf. Retrieved 2019-01-05. "The earliest case clearly involving the issue of whether a work prepared by a government employee could be copyrighted is Heine v. Appleton. Heine, a professional artist, had been a member of the crew that accompanied Admiral Perry to Japan and the China Seas."