Since your question appears to be about the effort to create/compose a photograph, I'm expanding the discussion to any art (including photography) because copyright laws equally apply and there is precedence regarding your question.
So, in general, in jurisdictions I know of, unless it's a work for hire, the creator of the art (a photograph,a painting, musical composition, essay, etc) owns the right.
This is true, even if it appears to be random or it appears there was no intellectual effort to create that piece of art. One example is a musical composer, John Cage, who composed much of his music using random numbers generated by iChing 'throws'. One of his copyrighted pieces was actually 4 minutes and 33 seconds of silence, called, not surprisingly, " 4'33" ". So, here is something, or rather about 4 and a half minutes of nothing, that is copyrighted. (Before someone says I'm being disrespectful to this famous avant-garde composer, I do respect his work and I actually worked with John Cage just before he died to use his random number technique to help him create some paintings. My job was to carry the rocks. )
Another example, this time of visual art, Gianni Motti, created a series of invisible art pieces, called Magic Ink - essentially they are blank canvases. You can see (or not see) those pieces of copyrighted art along with other similar copyrighted invisible pieces in this link. http://www.zimbio.com/pictures/bApkGpDSnKu/Press+Preview+Hayward+Gallery+Invisible+Art/browse
Although these artist did have skills, these examples show it is possible to have zero skills to copyright anything or even copyright nothing.
By the way, I'm not showing disrespect to any of the aforementioned artists/composers. I'm just pointing to the fact that even a box of nothing can be copyrighted, so it doesn't require skill to create a copyright-able work.