There isn't anything conclusive yet because there's still very little legal precedent. There was a case where someone made a comic which was essentially machine art with text over it, and there was one where the creation was completely unguided. In both cases they were denied protection because not enough human input was used.
There has yet to be a case where there was a greater amount of human input, such as using a method like controlnet to guide composition.
I think it will eventually come down to proving that a work involved significant human guidance rather than just luck.