A court of appeal, somewhere with a functioning one

She had done eleven years of background work and four speaking roles, and she had signed the standard rider because everybody signed the standard rider, and by the time she brought the action there were fourteen features with her in them that she had not been on the set of.

Her counsel argued dignity. The other side argued contract, and won on contract, and the case would have been forgotten if the court had stopped there.

It did not stop there. In order to dispose of the dignity claim it had to say what a likeness is, and the paragraph it produced ran to four sentences and has been quoted in every jurisdiction since.

It held that a likeness is not a part of a person in the way a limb is, nor a possession in the way a house is, but a pattern of recognition existing in third parties, which the person occasions but does not contain; that the law protects persons and property and has no third category; and that the appellant, having conveyed the pattern, retained everything the law recognises her as being.

The court plainly believed it was narrowing the case. Reading it now, you can watch it fail to notice what it has said.

Because it is true. That is why nobody could dislodge it. A likeness is a pattern in other people, and always was, and the sentence would have been just as true in 1400 — it simply had no commercial consequence in 1400, because the pattern could not be detached and shipped.

She lost, and went back to work, and is on record twice more, both times briefly and both times to say that she did not want to talk about it. The paragraph is still good law. It is taught in the first year, under property.