The U.S. Copyright Act clearly states that works produced by the U.S. government are ineligible for copyright protection.¹ This law reflects a sense that it would be inconsistent to give exclusive control and protection to works made by a government that is supposed to be made up “of the people, by the people, for the people.”² However, this prohibition on copyrightability has not been extended to works created by state or municipal governments.³ Certain works with legal authority created by public servants, like judicial opinions and statutes, cannot be copyrighted at any level of government as a matter of public policy.⁴ But courts have generally rejected the idea that this public policy rationale extends beyond this narrow set of circumstances to other works created by state or local government employees; as a result, other materials created by state or local governments may be copyrighted.⁵ This situation has led to some ambiguity regarding how copyright principles intersect with state access laws.