 Shortly after leaving the Factory, America hired a lawyer in order to persuade Warhol to pay him for his role in "My Hustler", which had become Warhol's first commercially successful film.Warhol, who never paid the actors who appeared in his films, eventually agreed to pay America $1,000 in several installments.In a December 1967 article in "The New York Times", America said he had received $500 from Warhol.