Once again shows the importance between independent contractor and employee The Introduction In a not so spooky ruling for creators, the U.S. Court of Appeals in Horror Inc. v. Miller, Case No. 18-3123 (2d Cir. Sept. 30, 2021) ruled the screenwriter of famous horror film Halloween was an independent contractor entitled to terminate the prior transfer of the screenplay. This is an important reminder to creators how important the difference between being an independent contrac