Thomas v. Carter

Background

Caze D. Thomas filed the action without a lawyer against Shawn Carter, Robert Williams, Gabrielle Wilson, and “A.K.A. Young Thug.” Thomas alleged copyright infringement involving his music. His original complaint also asserted claims under the Racketeer Influenced and Corrupt Organizations Act, but the court had previously dismissed that complaint as frivolous and allowed him 30 days to replead copyright claims. Thomas then filed an amended complaint and later submitted additional documents, including notices showing applications to register copyrights in some songs and other works.

Thomas alleged that his music was used in more than twenty songs and at least three albums. He asserted that some defendants or associated artists obtained his music through messages, internet postings, or hacking. He also alleged that public performances and changes in artists’ appearances contained hidden signals showing an effort to abuse him and infringe his copyrights.

Court’s Analysis

The court first held that the amended complaint was frivolous. A frivolous claim lacks a reasonable basis in law or fact. The court found Thomas’s allegations that Carter and other defendants created a large catalog of music from Thomas’s work, hacked his devices, and used public symbols to signal a coordinated effort against him to be wholly incredible, fanciful, and irrational.

The court separately held that the amended complaint failed to state a copyright-infringement claim. Such a claim requires allegations showing ownership of a valid copyright and copying of original elements of the work. The copyright-registration notice attached to the amended complaint concerned songs not identified as infringed. The later notices showed applications for registration, but Thomas did not allege that registrations had been obtained or that he had followed the required procedures if registration was refused. The court also found that Thomas did not explain how the defendants’ songs were similar to his songs or identify original elements that were copied. Repeatedly stating that the defendants “infringed” his intellectual property was not enough because that was a legal conclusion rather than supporting facts.

Disposition

The court dismissed Thomas’s claims with prejudice as frivolous and, alternatively, for failure to state a claim. It found that further amendment would be futile because the allegations were wholly incredible and because Thomas had already received notice of the deficiencies and an opportunity to correct them. The court denied as moot Thomas’s request to correct the caption to reflect “Young Thug’s” legal name, directed the clerk to close the case, and directed that a copy of the order be mailed to Thomas.