My understanding was that in Publications International, Ltd. v. Meredith Corp [0] the ruling came down fairly heavily on the side of recipes (including directions) being outside the domain of copyright. In that case a substantial number of recipes were copied out of a book and published elsewhere, but the court ruling stated:

“[The] recipes’ directions for preparing the assorted dishes fall squarely within the class of subject matter specifically excluded from copyright protection by 17 U.S.C. § 102(b).”

IANAL etc. Just curious if you have heard otherwise?

[0] - http://www.pddoc.com/copyright/publications_v_meredith.htm