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Holmes v. Smith
United States Court of Appeals for the Third Circuit
94 F. App’x 905 (2004)
Will Smith (defendant) and Jeffrey Townes formed a musical group called DJ Jazzy Jeff and the Fresh Prince. Clarence Holmes performed with the group for a few years as Ready Rock C. In 1986, Smith and Townes signed a recording contract. A few months later, Holmes alleged that Smith promised that Holmes would be an equal member of the group under the recording contract. Thus, Holmes executed an addendum to the recording contract, which stated that Holmes was signed to the same record label and would make the same provisions as Smith and Townes. The document did not refer to the earlier agreement, nor did it explicitly grant one-third of the group’s profits to Holmes. Further, neither Smith nor Townes signed the addendum. In 1990, Holmes stopped performing with the group, and he eventually fell into financial problems. Starting in 1997, Smith paid Holmes a total of $26,000, which he claimed were gifts. However, Holmes claimed this was evidence that Smith owed him a debt for one-third of the profits under the recording contract. Holmes brought suit in federal court, alleging breach of contract and quantum meruit. The district court found that Holmes’s claims were barred by the statute of limitations and accordingly dismissed them. Holmes appealed, arguing the statute of limitations should have been tolled until Smith began acknowledging the outstanding debt.
Rule of Law
Holding and Reasoning (Ambro, J.)
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