Anderson Bey v. Roc Nation LLC

Background

Bernard T. Anderson Bey proceeded without a lawyer and moved for a preliminary injunction and a temporary restraining order. He alleged that Roc Nation LLC, Sean C. Carter, also known as Jay-Z, and Live Nation Entertainment, Inc. conspired to exclude him from the hip hop industry and maintain a monopoly over the recording industry. He also alleged that those defendants influenced Coinbase, Renaissance Economic Development Corporation, the Internal Revenue Service, and the New York City Housing Authority in ways that harmed him and his company, T.Z.P.S. LLC.

The requested relief concerned several matters. Anderson Bey sought compensation and rescission of his contract with Coinbase so that he could access his cryptocurrency assets; access to facilities controlled by Live Nation; and an order preventing the New York City Housing Authority from accessing his apartment. His motions also raised allegations involving the New York Police Department and Albany County Family Court, including an alleged child-support-related arrest warrant and attempts to access his apartment.

The opinion addressed only the motions for preliminary injunctive relief. It did not decide the defendants’ pending motions to dismiss, Coinbase’s motion to compel arbitration or dismiss, or Anderson Bey’s other requests for discovery, a stay, partial summary judgment, and sanctions.

Legal standard

To obtain a preliminary injunction, a party must show likely irreparable harm, meaning harm that is actual and imminent and cannot be adequately repaired later, as well as either a likelihood of success on the merits or serious questions favoring the party with the balance of hardships in its favor. The requested relief must also serve the public interest. The court explained that the standard for a temporary restraining order is essentially the same. Because Anderson Bey represented himself, the court read his filings liberally and considered the strongest arguments they suggested.

Jurisdiction over newly raised allegations

The court held that the requested relief involving the New York Police Department and Albany County Family Court concerned allegations and parties not included in the amended complaint. Under Second Circuit precedent, a preliminary-injunction motion cannot introduce entirely different issues from those in the complaint. The court therefore lacked jurisdiction to grant relief concerning those matters.

The court also found no evidence in the record that a judge had confirmed an arrest warrant. The record contained only a family-court support magistrate’s recommendation that Anderson Bey be committed to jail, subject to confirmation by a judge. The court further stated that, even if an active warrant had been shown, it would have to refrain from considering claims challenging the family-court child-support order under the Rooker-Feldman doctrine, which generally prevents a federal district court from reviewing a state-court judgment. The court concluded that amending the complaint to add those claims would be futile.

The court did not decide whether an anti-filing injunction from Anderson Bey’s earlier related proceeding applied. It rejected the argument that the injunction barred him from filing these motions because the court had allowed him to file them. The court said it did not need to decide whether the injunction otherwise affected his likelihood of success because he failed to show irreparable harm.

Irreparable harm

The court denied the requested relief involving Coinbase because Anderson Bey had not shown why the alleged harm from the contract could not be repaired with money damages at the end of the case. Although rescission is an equitable remedy, he did not explain why monetary compensation would be inadequate. At the hearing, he did not identify harm that could not be addressed through money. The court therefore denied the preliminary injunctive relief requested against Coinbase.

The court also denied the requested relief involving Live Nation. Anderson Bey provided no specific facts showing that he had been denied access to particular facilities or that he was entitled to access them. He also did not show that any additional harm during the case was urgent or could not later be remedied with compensation.

As to the New York City Housing Authority, the court found that any harm based on a theoretical arrest warrant was speculative because Anderson Bey had not shown that a judge had issued such a warrant. The court separately considered the alleged XRF testing and possible eviction. It noted that Anderson Bey did not provide the videos he said showed an attempted illegal entry, and it explained that eviction is not automatically irreparable harm, particularly where there was no active eviction warrant or state eviction proceeding. The court therefore denied the requested preliminary injunctive relief against the New York City Housing Authority.

Disposition

Judge Andrew L. Carter, Jr. denied Anderson Bey’s motions for preliminary injunctive relief. The court specifically denied the preliminary injunctive relief requested against Coinbase, Live Nation, and the New York City Housing Authority. The opinion did not resolve the underlying claims on their merits.