Jackson v. Warner Music Group Corp.

Background

Jouan Jabez Jackson, appearing without a lawyer, filed a 304-page complaint against Warner Music Group Corp., Atlantic Recording Corporation, Atlantic Records, several individuals, and ABC Television Network. He alleged that he was the sole author and exclusive owner of musical compositions including “Assumption Day” and “Made A Champion,” and that the defendants copied original elements of those works into later songs and recordings. He identified songs associated with Brandy Norwood, Rodney Jerkins, and others, and sought damages, declaratory relief, and an injunction. His complaint also appeared to assert a state-law claim for “mental anguish.”

The court had previously allowed Jackson to proceed without paying filing fees. In reviewing such a complaint, the court was required to dismiss claims that were frivolous, failed to state a legally sufficient claim, or sought relief that could not be obtained from an immune defendant. The court also had to dismiss claims over which it lacked subject-matter jurisdiction. Although complaints filed without a lawyer are read generously, they still must provide a short and plain statement with enough facts to make the claimed entitlement to relief plausible.

Copyright claims

A copyright-infringement claim requires allegations showing both ownership of a valid copyright and infringement by the defendant. Jackson alleged that he had registered the works and received registration certificates, but he did not provide registration numbers, identifying information, or registration documents. The court stated that a search of the Copyright Office’s public catalog did not show that Jackson owned copyrights in the specified works. The catalog did show him as an apparent owner of other works and a possible co-owner of another work, but those works were not the ones identified as the basis for the claims.

The court therefore dismissed Jackson’s federal copyright claims for failure to state a claim. It granted him leave to file an amended complaint alleging facts showing that he owns the copyrights at issue and explaining how each defendant infringed them.

Limitations period

The court separately ruled that, even if Jackson owned the copyrights, most of the alleged infringement claims appeared to be untimely. Federal copyright claims generally have a three-year limitations period, and the relevant claims accrue when the copyright owner discovers, or with reasonable diligence should have discovered, the infringement. Because Jackson filed the complaint on November 16, 2023, claims that accrued before November 16, 2020 appeared untimely.

Jackson did not allege when he discovered, or should have discovered, the alleged infringements. The court therefore also dismissed claims that accrued before November 16, 2020 for failure to state a claim. It granted leave to amend so that Jackson could allege facts showing why those claims were timely or why the limitations period should be extended for equitable reasons.

State-law claims and disposition

After dismissing the federal claims, the court declined to exercise supplemental jurisdiction—the court’s authority to hear related state-law claims—in the same action. The court therefore declined to consider Jackson’s remaining state-law claims.

The court dismissed the action and the federal claims for failure to state a claim, while granting Jackson 30 days to file an amended complaint. If he did not timely amend and could not show good cause for the failure, the court said it would direct the Clerk to enter a judgment dismissing the action. The court also certified that an appeal would not be taken in good faith and denied fee-free status for purposes of an appeal. Because Jackson was allowed to amend, the court directed the Clerk not to close the action at that time. The order did not determine whether the defendants actually infringed Jackson’s copyrights.