In 1985, Snyder and CCNV hired sculptor James Earl Reid to create a display for the annual Christmastime Pageant of Peace in Washington which would dramatize the plight of the homeless. The display, titled "Third World America," featured a nativity scene in which the Holy Family was represented by contemporary homeless people huddled around a steam grate. The figures were atop a pedestal that stated "And Still There is No Room at the Inn." In 1986, Snyder and CCNV wanted to take "Third World America" on tour, but Reid refused. Snyder and CCNV sued Reid, claiming that "Third World America" was a work for hire under § 101 of the United States Copyright Act. In the case "Community for Creative Non-Violence v. Reid", the U.S. Supreme Court ruled the sculpture was not a work for hire because Reid was not an employee under the general common law of agency. Thus, the work was not subject to the § 201(b) rule that when a work is made for hire, the employer is considered the author.