That's how the Boston Globe described the Court's ruling in Springfield on Friday. (See also Tammy Daniels, iBerkshire.com: "Ponsor ... said an unfinished work doesn't qualify for protection under VARA.")
I'll have (lots) more to say on this angle in the coming days, but for now I just want to note that this is exactly the sort of thing I was referring to in my post, "The Joe Thompson Rules." The fact is that, in pursuing its "victory" over Büchel, MASS MoCA has done serious damage to the cause of artists' rights generally. As Sergio Muñoz-Sarmiento has said, "their claim that their lawsuit against Büchel will not have any negative consequences on legal protection for visual artists and their artworks is ridiculous to say the least. In summation, MASS MoCA has in effect NOT narrowed the legal decision to apply solely to Büchel, but rather guaranteed that all artists are now subject to have their artistic ideas exhibited and shown to the public in any state of completion and at any time by setting the legal and binding precedent that 'VARA does not address the display of unfinished work or the display of materials assembled for use in a work of art.'"