Anderson Bey v. Roc Nation LLC
- Andrew Carter
- 1:24-cv-02295
- U.S. District Court · Southern District of New York
- 4
In Anderson Bey v. Roc Nation, Judge Carter denied Anderson Bey’s motions for discovery and a stay while defendants’ dismissal motions remained pending.
Bernard T. Anderson Bey’s requests for discovery and a stay were denied; the defendants’ pending motions to dismiss were not decided by this opinion.
What happened
In Anderson Bey v. Roc Nation LLC, Bernard T. Anderson Bey, representing himself, asked to conduct discovery and pause deadlines while the defendants’ motions to dismiss his amended complaint were pending. Coinbase had also asked the court to require arbitration or dismiss the complaint.
The court said discovery generally is not available to help a plaintiff build a claim before showing that the complaint states a legally sufficient claim. It explained that the dismissal motions would be decided using the well-pleaded facts in the complaint, treated as true, rather than by weighing disputed evidence.
Judge Andrew L. Carter, Jr. denied both motions for discovery and for a stay. The court also directed the Clerk to terminate ECF Nos. 28 and 33 as moot.
The detailed version
- Anderson Bey v. Roc Nation LLC · No. 1:24-cv-02295
- Andrew Carter
- Feb. 20, 2025
Background
Bernard T. Anderson Bey filed this action on March 27, 2024, and filed an amended complaint on July 30, 2024. He is proceeding without a lawyer. On November 15, 2024, Roc Nation, Carter, Live Nation, and NYCHA moved to dismiss the amended complaint. Coinbase separately moved to compel arbitration or, alternatively, to dismiss the amended complaint.
After a December 3, 2024 status conference, the court allowed Anderson Bey to file motions seeking discovery and a stay. Anderson Bey asked for discovery to defend against the pending dismissal motions and sought a stay of the deadlines relating to those motions.
Legal standard
The court relied on the general rule that a litigant must state a claim before obtaining discovery. It explained that allowing discovery so a plaintiff can piece together a claim would undermine Federal Rule of Civil Procedure 12(b)(6), which permits dismissal when a complaint fails to state a legally sufficient claim.
For a Rule 12(b)(6) motion, the court must accept well-pleaded factual allegations as true, draw reasonable inferences in the plaintiff’s favor, and decide whether the complaint plausibly states a claim for relief. The court does not weigh evidence that might be presented at trial at this stage.
Court’s reasoning
The court rejected Anderson Bey’s argument that his use of “notice pleading” entitled him to discovery. The court said the cited precedent did not establish a right to discovery merely because a plaintiff claims to have given defendants notice of the claims.
The court also rejected the argument that disputed facts in the pending dismissal motions required discovery. Because the motions would be decided based on the complaint’s well-pleaded allegations and legal sufficiency—not on resolving factual disputes—the court concluded that discovery was unnecessary. The court likewise found no basis to stay the deadlines for the dismissal motions.
Disposition
The court denied Anderson Bey’s motion for discovery and denied his motion for a stay. The conclusion states that both motions were denied. The Clerk of Court was directed to terminate ECF Nos. 28 and 33 as moot.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.