White v. Warner Music Group

Background

Brian K. White, who also uses the names DJ Coldblooded, Brian Psalms, and Amir Beats, sued Warner Music Group and 300 Entertainment Sparta Distribution. He proceeded without a lawyer and had received permission to proceed without prepaying court fees. White asserted state-law claims concerning a contract involving ownership of his music and also alleged copyright infringement.

White alleged that Sparta claimed ownership of his publishing and songs, although he said he was mentally ill when he signed the publishing agreement. He also alleged that he had not received a publishing payment, that Lyor Cohen had interfered with releases and playlisting, and that he suffered financial and emotional harm. He requested declaratory relief, an order concerning his releases, publishing, and other property, and $9,000,000 in damages.

After filing the complaint, White asked to add Kobalt, Paramount Pictures Corporation, and Pandora as defendants and submitted additional letters containing facts related to his claims. The court addressed the claims against the named defendants—Warner Music Group and 300 Entertainment Sparta Distribution—in this order.

Court’s analysis

Because White was allowed to proceed without prepaying fees, the court was required to screen his complaint. It had to dismiss any claim that was frivolous, malicious, failed to state a legally sufficient claim, sought money from an immune defendant, or fell outside the court’s subject-matter jurisdiction. The court also explained that self-represented pleadings are read generously, but still must provide a short and plain statement of facts showing entitlement to relief.

The court concluded that it could not determine what claim White intended to bring. His allegations appeared to assert that the defendants breached a publishing contract under which they received ownership of his copyrights in exchange for royalties. But he also alleged that he lacked the competence to sign the agreement, which appeared to challenge the agreement’s validity. He did not state when the agreement was signed, when a breach first occurred, how often it was breached, or why he was entitled to royalties.

The court also noted that White appeared to assert copyright infringement, which could suggest that no valid publishing contract existed. It therefore directed him to clarify whether he was asserting contract claims, copyright claims, or both, and to identify the facts supporting each claim against each named defendant.

The court stated that White alleged the parties were diverse and that the amount in controversy exceeded $75,000. On that basis, it found that it could exercise authority over any state-law claims under diversity jurisdiction. The court added that any new defendants in an amended complaint would also have to be diverse from White and therefore could not reside in New Jersey, which the complaint identified as White’s state of residence.

Disposition

The court granted White leave to file an amended complaint within 60 days. The amended complaint had to replace, rather than supplement, the original complaint and had to repeat any facts or claims that White wanted the court to consider. The court instructed him to provide the names and titles of relevant people, descriptions of relevant events and their approximate dates and locations, his injuries, and the relief sought.

No summons would issue at that time. The court stated that if White failed to amend within the allowed period and could not show good cause, the complaint would be dismissed for failure to state a claim. The court also certified that an appeal would not be taken in good faith and denied White permission to proceed without prepaying fees for an appeal. The order did not decide whether White’s contract or copyright claims had merit.