Edwards v. Universal Music Group, Inc.
- William Orrick
- 3:20-cv-02373
- U.S. District Court · Northern District of California
- 2
In Edwards v. Universal Music Group, Judge Orrick granted UMGI’s motion to dismiss without prejudice because Edwards had dropped it from his amended complaint.
Universal Music Group, Inc. was removed from the case without prejudice; the opinion also directed Leshon Edwards to address whether the remaining defendants had been served with the amended complaint.
What happened
In Edwards v. Universal Music Group, Inc., Leshon Edwards originally sued Universal Music Group, Inc. and four other defendants, alleging accounting, fraud and concealment, and unjust enrichment claims against Universal.
After Universal filed a motion to dismiss for failure to state a claim, Edwards filed an amended complaint that removed Universal as a defendant. Edwards did not oppose dismissal but argued it should be without prejudice.
Judge William H. Orrick granted Universal’s motion to dismiss without prejudice. He explained that the case was still in its early stages and that the court had not considered whether any complaint’s allegations were legally sufficient.
The detailed version
- Edwards v. Universal Music Group, Inc. · No. 3:20-cv-02373
- William Orrick
- Oct. 28, 2020
Background
Leshon Edwards filed the action on April 8, 2020, and filed a corrected complaint the next day. The complaint named Universal Music Group, Inc. (UMGI) as one of five defendants and asserted claims against UMGI for an accounting, fraud and concealment, and unjust enrichment.
UMGI moved to dismiss under Federal Rule of Civil Procedure 12(b)(6), which allows dismissal for failure to state a legally sufficient claim. Before responding to that motion, Edwards filed a First Amended Complaint that dropped UMGI as a defendant.
Ruling
Because the amended complaint no longer named UMGI, the court had previously denied UMGI’s first motion to dismiss without prejudice as moot. UMGI then filed another motion asking to be dismissed with prejudice. Edwards did not oppose dismissal but argued that it should be without prejudice.
The court distinguished the cases UMGI cited, explaining that this case was still in its early stages and that the court had not addressed the sufficiency of the allegations in any of the complaints. The court therefore granted UMGI’s motion to dismiss without prejudice.
Other Case Information
The court noted that it was unclear whether the remaining defendants had been served with the First Amended Complaint. Edwards was ordered to address that issue at the upcoming Case Management Conference.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.