Cagle v. Hybner
Tennessee Court of Appeals
2008 WL 2649643 (2008)
- Written by Liz Nakamura, JD
Facts
Chris Cagle (plaintiff), a songwriter, entered into an exclusive songwriter agreement (ESA), a type of personal service contract, with Mark Hybner (defendant). At the relevant time, Hybner also acted as Cagle’s manager and publisher. Under the ESA, Cagle was required to write 90 marketable, commercial-quality songs at a rate of 18 songs per year. Hybner had sole discretion to determine whether the songs Cagle wrote were of sufficient quality. The ESA acknowledged that Cagle’s services were unique and extraordinary. Several months later, Cagle entered into a recording contract with Virgin Records. Cagle and Hybner’s relationship broke down, and Cagle fired Hybner as his manager. Cagle then filed an action seeking a declaratory judgment that the ESA was invalid and unenforceable. When Cagle filed his action, he had written only 13 songs for Hybner. Hybner filed a counterclaim seeking both specific performance of the ESA and an injunction barring Cagle from composing songs for Hybner’s competitors until Cagle wrote all 90 songs. The ESA specifically authorized Hybner to seek equitable relief. The trial court held that the ESA was enforceable and granted Hybner the requested equitable relief. Cagle appealed.
Rule of Law
Issue
Holding and Reasoning (Clement, J.)
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