Disney Wins Moana Copyright Infringement Lawsuit. A federal jury in Los Angeles delivered a decisive victory for Walt Disney Animation Studios yesterday, rejecting claims that the studio’s 2016 animated hit “Moana” infringed on the copyright of independent animator Buck Woodall’s outlines and script for “Bucky the Surfer Boy.”
After deliberating for just under three hours, the six women and two men jury unanimously found that Disney never had access to “Bucky the Surfer Boy.”
Case Background
Woodall’s lawsuit centered on several alleged similarities between his unreleased “Bucky the Surfer Boy” project and Disney’s “Moana.” Woodall’s case highlighted narrative parallels, including both stories featuring young protagonists who venture onto the ocean against family wishes to rescue their imperiled home islands.
His complaint detailed additional claimed similarities: mystical animal spirits serving as guides, meaningful necklace artifacts driving plot developments, and hook-wielding, tattooed demigod characters appearing in both narratives.
The legal filing traced a potential path of access, stating that Woodall presented his “Bucky” materials to producer Eric Marchick in 2003, and alleged these creative elements eventually found their way to Disney’s animation team, ultimately influencing the development of “Moana.”
The plaintiff sought damages based on “Moana’s” commercial success, which has generated just under $700 million in worldwide box office revenue since its 2016 release, plus additional earnings from merchandise, home media sales, and streaming.
The Plaintiff’s attorney argued that Woodall gave the “Bucky” outline to Jenny Marchick who worked for Mandeville Films, a company that had a contract with Disney. Disney’s attorneys argued that there was no evidence that Disney had ever received or worked with Marchick on “Moana.”
Disney’s Approach to Animation Development
While not specific to any particular lawsuit, Disney’s typical approach to developing animated features like “Moana” involves documented creative processes that often serve as defense mechanisms in intellectual property disputes.
For “Moana,” which was released in 2016, Disney did establish what they called the “Oceanic Story Trust” – a group of anthropologists, cultural practitioners, historians, and linguists from across the Pacific Islands who consulted on the film. This approach was publicly documented in numerous interviews and behind-the-scenes features.
Directors Ron Clements and John Musker, who helmed the project, have spoken extensively in media interviews about their research trips to Fiji, Samoa, and Tahiti during the pre-production phase. According to Disney’s public statements, the development of “Moana” took approximately five years from concept to completion.
Disney typically maintains robust documentation of its creative development timelines specifically because major studios are frequent targets of copyright litigation. This practice allows them to demonstrate when and how creative decisions were made, which can be crucial evidence in copyright disputes.
Disney’s Copyright History
Disney has faced various copyright challenges over the years related to its animated features. In these cases, courts have often focused on whether the alleged similarities involve protected expression or merely unprotectable elements such as general themes, ideas, or scenes à faire (elements that naturally flow from a particular genre or setting).
For example, in Esplanade Productions, Inc. v. The Walt Disney Company (C.D. Cal. 2017), a federal court dismissed claims that “Zootopia” infringed on the plaintiff’s work, finding that the similarities were primarily in unprotectable concepts rather than specific expression.
Similarly, in Alfred v. Walt Disney Company (9th Cir. 2020), the Ninth Circuit affirmed that “Pirates of the Caribbean” did not infringe on writers’ screenplay, noting that many of the similar elements were scenes à faire that naturally flow from the pirate genre.
Industry Implications
The jury ruling reinforces the challenges independent creators face when bringing copyright claims against major studios, particularly involving commercially successful properties.
This outcome may influence how studios document their creative development processes and how independents approach protecting their work when submitting ideas or concepts.
Additionally, this case highlights the ongoing tension in copyright law between protecting original expression and allowing creators to draw upon common themes, settings, and narrative elements that cannot be monopolized by any single artist.
Disney’s attorneys declined to comment when existing the courtroom and Woodall’s attorney said he was “disappointed” and would consider his client’s options as they move forward. Woodall filed a seperate lawsuit for Moana 2 and that case is still pending.
