Universal-MCA Music Publishing v. Bad Boy Entertainment, Inc.
New York Supreme Court
2003 WL 21497318, 2003 N.Y. Slip Op. 51037(U) (2003)
- Written by Kyli Cotten, JD
Facts
Universal-MCA Music Publishing (MCA) (plaintiff) was a publishing company that owned exclusive rights to all musical compositions written by Todd Gaither, Kelly Price, and Jeremy Graham (MCA cowriters) (plaintiffs). Sean Combs (defendant) was a songwriter and co-owner of the recording company Bad Boy Entertainment, Inc. (Bad Boy) (defendant). In 1996, Combs, in his capacity as a songwriter, and Bad Boy entered into a recording agreement that included a controlled-composition clause, which limited the amount of royalties the record company must pay for compositions to less than the minimum rate set by law. In 1997, Combs and the MCA cowriters coauthored several songs and expressly agreed on each writer’s ownership percentage and royalty rate. The MCA cowriters and MCA alleged that they made numerous attempts to recover their royalties. Bad Boy asserted to MCA that none were due per the controlled-composition clause. MCA and the MCA cowriters filed suit, alleging that Combs and Bad Boy entered the recording agreement to intentionally deprive them of royalties, thereby breaching Combs’s fiduciary duty to them. They further alleged that, as the president and CEO of Bad Boy, Combs profited enormously from the recording agreement to the detriment of his cowriters on the songs. Combs and Bad Boy moved to dismiss the case for failure to state a claim and argued that no fiduciary relationship existed between Combs and the MCA cowriters.
Rule of Law
Issue
Holding and Reasoning (York, J.)
What to do next…
Here's why 815,000 law students have relied on our case briefs:
- Written by law professors and practitioners, not other law students. 46,300 briefs, keyed to 988 casebooks. Top-notch customer support.
- The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
- Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
- Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.