Anderson Bey v. Rocnation LLC

Background

Bernard T. Anderson Bey, proceeding without a lawyer, brought antitrust and civil-conspiracy claims against Live Nation Entertainment, Inc., Roc Nation, LLC, and Shawn C. Carter. The claims arose from Bey’s allegations that the defendants suppressed him and his brand, “Team Zenith Platinum Status Inc.”

On May 1, 2023, the court adopted two reports by Magistrate Judge Jennifer E. Willis and dismissed Bey’s claims against all defendants for failure to state a claim. The opinion does not revisit the merits of that earlier dismissal.

Motions and Report

Bey later moved under Federal Rules of Civil Procedure 52(b) and 59(e) to set aside findings of fact and obtain a new trial. He also moved for preliminary injunctive relief and sanctions under Rule 11(b). Judge Willis recommended denying all three motions. At the defendants’ request, she also recommended an anti-filing injunction requiring Bey to file a motion for permission and an accompanying statement before making additional filings in the matter.

Bey objected to the report. The court explained that specific objections would receive fresh review, while general or conclusory objections would be reviewed only for clear error. The court found that Bey’s objections were not sufficiently specific and largely addressed matters outside the report, including whether he should have been allowed to supplement his pleadings and whether the defendants committed fraud on the court. The court therefore reviewed the report for clear error and found none.

Ruling

Judge Engelmayer adopted Judge Willis’s report in full and denied Bey’s motions. The court also adopted the content and scope of the anti-filing injunction described in the report, including its requirement that Bey seek permission and provide a statement before filing additional papers in the matter. The opinion states that the court did not consider a further response filed by Bey because it was procedurally improper and largely duplicated his earlier objections.