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The Voyager episode "Author, Author" is basically a shameless ripoff homage to the TNG era episode of "Measure of a Man". In that, an android known as Data has to face a tribunal to be declared property, or a sentient person. In "Author, Author", a hologram has to face a crooked publisher in court to defend his rights and personhood when he is told he has none. Of course, the Voyager episode happens a few years in continuity after the landmark case of Data being declared a Person.

Yet while the episode has references to other Star Trek series, the episode has no references to the episode it is copying. The Doctor at one point compares his holo-novel to the Vedic telling about the occupation of Bajor (From Deep Space Nine).

Why did they not drop even a reference to Data? It would make sense in a court case, to reference a previous ruling. Something as landmark as an Android being declared a Person, when said android was also a Star Fleet officer, also holds the same problem of "is his reactions just programmed instead of sentient?", and how recent it was.

Production notes or word of god only. No speculation...

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You may not like or agree with what I am about to say, but please hear me out.

I don't think production notes or word of God is going to help answer your question here. The question assumes that the writers were invested enough in the show to pay attention to such details. If the writers had overlooked or ignored that detail, you aren't going to find it in any official source.

Star Trek Voyager has not been known for its consistency or attention to detail. I'll back this statement up with some examples:

  • In the episode "30 days" Tom Paris has a childhood flashback. The child version of Paris has brown eyes. Adult Tom Paris has blue eyes.
  • Within the series, it had been established that Janeway often broke the Prime Directive, yet in "30 days" Janeway hypocritically punishes Paris for doing the same thing.

If the show couldn't even keep a character's eye color straight when selecting the child actor or establish Janeway as a consistent character, what makes you think they would remember to add a nod in a court arguement about a similar case when the script was likely only skimmed before being adapted.

Contrast this with TNG writers able to avoid plot holes in Worf's ongoing personal redemption saga spread throughout the series. TNG's episode "The Naked Now" was a remake of TOS's "The Naked Time", but writer's made sure that mentions of Captain Kirk's crew experiencing the same phenomena were written in as a nod. I'd chalk this up to the writer's being invested enough in the show to be attentive to these details. That's the best explanation I can offer, but as this question is at least 6 months old, I think you'll be hard pressed to find a better one.

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    (1) The actor's eye color is a ridiculuous argument to make. Sure, it's an inconsistency, but you have no reasonable basis to expect the showrunners to find a child of the appropriate age, acting chops, hair color, eye color, general looks of the adult actor, and also be available at the time of shooting for an affordable price. (2) Janeway can be inconsistent in punishing Paris without that being irrefutable evidence of bad writing. Maybe Janeway is simply being a hypocrite. Maybe she considers Paris' transgression unwarranted, but considers her own actions "obviously necessary".
    – Flater
    Commented Sep 27, 2017 at 15:28
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I'm sorry, I'm not directly answering your question ("Why didn't they mention Data?"). I couldn't find any production notes, and I couldn't reach the story author (Brannon Braga) or the director (David Livingston).

But - I do have a decent in-universe explanation of why Data's story didn't matter.


Data was a unique being that Starfleet discovered, consisting of hardware that had yet to be reproduced. This ultimately led to him being granted the full legal status of "person".

The Doctor was pure software, and was entirely designed and programmed by Starfleet. Even after litigation, he still wasn't granted the status of "person". He was only granted the "economic" status of "Artist", which gave him the right to control his holonovel.


Pulled from Memory Alpha (the Star Trek wiki):

While it had been determined that Data, although being a machine, was not Starfleet property and thus had the right to choose what to do with his life (and thus could most likely be considered a person), it seems the whole process had to be repeated for The Doctor and fellow holograms. The situation here is even more complex than with Data, since Data was a unique single being who was not created by Starfleet (he was found by Starfleet personnel), while holograms were programmed and designed by Starfleet and integrated into ships, space stations and other Starfleet property. In the end, it is not acknowledged in this episode that The Doctor is a person, but he is rather granted the status of an artist.

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    The problem is that nonetheless, "Measure of a Man" established legal precedent. In fact it's especially important because of this line: PICARD: A single Data, and forgive me, Commander, is a curiosity. A wonder, even. But thousands of Datas. Isn't that becoming a race? And won't we be judged by how we treat that race? THAT IS EXACTLY WHAT STARFLEET HAS DONE.
    – Ambaryerno
    Commented Oct 1, 2020 at 0:52

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