Disney has been cleared of copyright infringement in a lawsuit over the animated film ‘Moana’. The case represents one of several high-profile intellectual property disputes in the entertainment industry in recent years.
The move came after a jury in Los Angeles ruled in favor of the entertainment giant, with the verdict delivered on Monday (10.03.25) following a two-week trial in federal court. Copyright infringement cases have become increasingly common as studios continue to produce content based on various source materials.
Buck Woodall, a screenwriter based in New Mexico, had filed the lawsuit in 2020, alleging ‘Moana‘ was based on his work, ‘Bucky the Wave Warrior’. Woodall had developed his screenplay for several years before attempting to share it with industry professionals.
An eight-member jury ruled unanimously Disney did not have access to Woodall’s 2011 screenplay or earlier treatments. The legal standard for proving access in copyright cases is often a significant hurdle for plaintiffs in the entertainment industry.
After deliberating for less than three hours, jurors determined access had not been established, making it unnecessary to assess whether the two works were substantially similar. This type of quick deliberation suggests the jury found the evidence regarding access particularly clear-cut.
Buck alleged both projects centered on teenagers who defy their parents to embark on perilous journeys to save a Polynesian island. Coming-of-age narratives involving heroic journeys are frequently used in animated films across many studios.
He also cited other similarities, including celestial navigation, a tattooed demigod and surviving a storm at sea. These elements have deep roots in Polynesian mythology and cultural traditions throughout the Pacific Islands.
According to Buck, he pitched the project in 2004 to his sister-in-law’s stepsister, who was then an assistant at a live-action production company on the Disney lot. The entertainment industry relies heavily on professional connections, making such personal relationships potentially significant in legal disputes.
The assistant later inquired whether Walt Disney Animation Studios would accept a submission but was informed that it would not. Major studios typically implement strict submission policies to protect themselves from legal claims regarding idea theft.
Disney argued ‘Moana’ was independently developed years later and said no evidence linked Buck’s work to the filmmakers. The studio invested heavily in research trips to various Pacific Islands during the development process.
The company’s lawyers pointed to key differences between the two works with its legal team saying in a motion: “Bucky is white; Moana is Oceanian. Bucky is from the mainland U.S.; Moana is indigenous to the fictional island of Motunui.
“Bucky lives in the modern day; Moana lives millennia in the past. Bucky is an ordinary teen; Moana is the future chief of her people. Bucky wants to learn to surf, while Moana wants to continue her people’s proud history as the greatest ocean voyagers the world has ever known.” These distinctions highlight fundamental differences in character, setting, and thematic elements.
A judge ruled in November most of Buck’s claims were barred by the statute of limitations, as the film was released in 2016. Copyright law includes specific time limitations to ensure timely filing of claims.
But a claim against Buena Vista Home Entertainment, Disney’s home video subsidiary, was allowed to proceed due to the DVD release in 2017. This legal strategy attempted to circumvent the statute of limitations by focusing on later distribution channels.
Following the verdict, Disney’s lawyers declined to comment. The studio has faced similar lawsuits regarding other successful animated features in the past.
Buck’s lawyer said he was “disappointed” and would consider his client’s options. Appeals in copyright cases face significant challenges, particularly when a jury has ruled on factual matters like access to the original work.
Buck also filed a separate lawsuit in January this year, alleging ‘Moana 2‘ infringes on his work – with the case remaining pending. The sequel continues the story of the popular character and will likely face similar scrutiny regarding its source material and development process.
The case highlights the challenges creative professionals face when attempting to prove copyright infringement against major studios, particularly when dealing with stories that incorporate cultural elements and common narrative structures.
