This dismissal is particularly important for Murphy, as de Havilland winning this case could open up issues for his future work. The American Horror Story creator is, after all, famous for crafting television stories based on real people and events. Season 1 of American Crime Story, for example, told the story of the O.J. Simpson trial, while the second season pulled back the layers on the murder of Gianni Versace . The latter season was called a "work of fiction" by Versace's family. Had de Havilland won her lawsuit, it's possible that other people who were not entirely pleased by Murphy's portrayals could attempt to take the same legal action.