Young v. Mintz
- Laura Swain
- 1:21-cv-04351
- U.S. District Court · Southern District of New York
- 5
In Young v. Mintz, Judge Swain dismissed the complaint for failing to state a claim, allowed 30 days to replead copyright claims, and denied appeal fee-waiver status.
The order affected Young’s claims against Carol Mintz, Warner Brothers Records, and Warner Brothers Entertainment. It dismissed the complaint for failure to state a claim, dismissed the constitutional claims against the private defendants, allowed 30 days to replead only the copyright claim, and denied fee-waiver status for an appeal.
What happened
Young v. Mintz involved allegations that Carol Mintz, Warner Brothers Records, and Warner Brothers Entertainment stole Young’s music and were involved in other alleged misconduct. Young, who was representing himself, sought money damages and access to medical records.
The court treated the music allegations as a possible copyright claim but found that Young did not allege ownership of a valid copyright, identify the music, or explain how the defendants copied it. The court also dismissed the constitutional claims because the defendants were private parties, not government actors who can generally be sued under the federal civil-rights statute.
Judge Laura Taylor Swain dismissed the complaint for failure to state a claim, gave Young 30 days to replead the copyright claim, and denied him fee-waiver status for any appeal. The court did not enter a civil judgment at that time.
The detailed version
- Young v. Mintz · No. 1:21-cv-04351
- Laura Swain
- June 15, 2021
Background
Young filed the action invoking federal-question jurisdiction and was allowed to proceed without paying filing fees. He represented himself. He alleged that, after submitting music to Warner Brothers Records, his music was stolen and used for financial gain. He also alleged computer crimes, harassment, defamation, assaults, unauthorized medical procedures, electrical shocks, and other conduct. The defendants were identified as Carol Mintz, Warner Brothers Records, and Warner Brothers Entertainment. Young sought money damages and access to his medical records.
Court’s Review
Because Young was proceeding without paying filing fees, the court was required to screen the complaint and dismiss it if it was frivolous, failed to state a claim for relief, sought relief from an immune defendant, or did not establish the court’s jurisdiction. The court was required to read a self-represented litigant’s allegations liberally, but the complaint still had to provide enough factual detail to make a claim plausible under the federal pleading rules.
Copyright Claim
The court interpreted Young’s allegations that the defendants stole his music as asserting copyright infringement. A copyright-infringement claim requires allegations that the plaintiff owns a valid copyright and that the defendants copied original parts of the protected work without authorization.
The court found that Young did not allege that he owned a valid copyright, did not allege that the defendants copied his work, did not identify the music allegedly stolen, and did not explain how the defendants infringed protected material. The court therefore dismissed the copyright claim for failure to state a claim.
Constitutional Claims
To bring a civil-rights claim under 42 U.S.C. § 1983, a plaintiff must allege both a violation of a federal right and action by someone acting for a state or local government. The court concluded that the defendants were private parties who did not work for a state or other government body. It therefore dismissed any constitutional claims against them under that statute.
The court also noted that Young’s allegations concerning implants appeared to be frivolous, meaning they appeared to lack an arguable basis in law or fact. The opinion did not grant leave to replead those allegations.
Disposition
The complaint was dismissed for failure to state a claim. The court granted Young 30 days’ leave to replead the copyright-infringement claim, although it stated that the defects likely could not be cured by amendment. A civil judgment would not issue at that time. The court also certified that an appeal would not be taken in good faith and denied Young permission to proceed without paying fees for purposes of an appeal.
Read the full 5-page opinion on CourtListener, the free public archive maintained by the Free Law Project.