"Great expense" isn't enough in all jurisdictions. In a sweat-of-the-brow jurisdiction like the UK it would be, but I'm not necessarily convinced that it would be in the US.
"I bought a really kickass camera; all my photos are now copyright" vs "I used my phone's camera; I don't have copyright on all my images" seems like a rather ludicrous difference too. Because things like time are hard to measure and irrelevant ("I waited outside all day for sunset" vs "I lucked out and got there at the perfect time to take it"), and props, when it's literally -one- object, being taken from the most obvious angle, also seems a bizarre thing to consider. Not saying what is or is not the law, and in what jurisdictions, just that it seems weird to consider it anywhere.
