Copyright in America was once much more narrowly defined than it is today. A famous example: in 1853, Harriet Beecher Stowe sued a publisher for printing an unauthorized German translation of her book, Uncle Tom's Cabin.
She lost the case.
The judge essentially ruled the translation was an original work based on her ideas only, not her exact words.
https://www.copyrighthistory.org/cam/tools/request/showRecord.php?id=record_us_1853b