Choe v. Fordham University School of Law
Jerry Choe sued Fordham University School of Law and Fordham International Law Journal (ILJ) alleging mutilation of his published Comment. He claimed violations of § 43(a) of the Lanham Act and federal common law "moral rights," along with state claims like libel and breach of contract. Choe contended that the ILJ published a "garbled and distorted" version of his work, containing numerous substantive and typographical errors, which made him appear sloppy. The court examined whether the published Comment substantially departed from the original to the extent that Choe could not be considered its author, referencing cases like Gilliam v. American Broadcasting Co. The court found that despite the alleged errors, Choe himself admitted readers could "uncover the essential meaning" of his Comment, distinguishing it from cases of radical alteration. The court also dismissed the federal common law "moral rights" claim, stating that such a claim is not recognized in this Circuit. Consequently, defendants' motion for summary judgment was granted, and the complaint, including pendent state claims, was dismissed due to lack of federal jurisdiction.