In a case similar to this one, the Ninth Circuit recently held that, notwithstanding a spiritual book's "celestial" or "divine" origins, the originality requirement necessary for a valid copyright was satisfied because the human beings who "compiled, selected, coordinated, and arranged" the book did so "'in such a way that the resulting work as a whole constitutes an original work of authorship.'" Urantia Found. v. Maaherra, 114 F.3d 955, 958 (9th Cir. 1997) ("Urantia") (quoting 17 U.S.C. § 101). The parties in Urantia agreed that the words in "The Urantia Book" were authored by divine spiritual beings, who initially communicated with a psychiatric patient who wrote the words down by hand. See Urantia, 114 F.3d at 957; Urantia Found. v. Burton, 210 U.S.P.Q. 217, 1980 WL 1176, at *1 (W.D. Mich. 1980) ("Urantia II"). The handwritten manuscript was then typed out by the patient's psychiatrist. Although it is not entirely clear from the opinions of the courts, at some point in the process it appears that a group of people, the "Contact Commission," came to know the manuscript, discussed it, and, at the prompting of the divine beings, posed questions to the divine beings. The answers to those questions became the series of teachings that formed the Urantia Book. See id.; Urantia, 114 F.3d at 957. The Ninth Circuit held that the choice of questions by the Contact Commission, notwithstanding guidance from the divine beings, "materially contributed to the structure of the Papers, to the arrangement of the revelations in
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