In Douglas v. Stokes, the parents of a freak child, who died shortly after birth, engaged the defendant, a photographer, to take photographs of the nude body of the child, it being agreed that he was to make twelve pictures and no more. The defendant made additional photographs without the consent of the parents, one of which he copyrighted. It was held that the parents could recover.

In Douglas v. Stokes, 149 Ky. 506, 149 S.W. 849, 42 L.R.A. (N.S.) 386, Ann. Cas. 1914B, 374, the action was against a photographer who had been employed by the plaintiff to take a photograph of the corpses of the plaintiff's children, who had been born Siamese twins.