Hollywood industry lawyers in the 1920s, 1930s, and 1940s took the position that an exclusive personal services contract should be treated as suspended during the periods when the artist was not actually working.
[1]) De Havilland's legal victory reduced the power of the studios and extended greater creative freedom to performers, starting with herself.
[7] Although Jack Warner tried to discourage other studios from hiring her, she eventually found work with Paramount Pictures, where she won her first Best Actress Oscar for To Each His Own (1946).
[1][8] While today's film and TV actors have enjoyed the higher compensation and greater creative freedom intended by Section 2855, music artists have not.
Johnny Carson, then host of The Tonight Show, used the De Havilland law to break his contract with NBC and began aggressively considering a bid from rival network ABC; although he ultimately decided to remain with NBC, his use of the law allowed him to extract major concessions from the network, including a reduced workload, increase in pay and ownership of the show.