A New York judge dismissed a class action lawsuit brought by Black Sheep against Universal Music Group. According to court documents obtained by Reuters, Judge Jennifer Rochon determined the statute of limitations for Black Sheep’s claims had passed in a ruling on Monday (November 20).
Black Sheep members Dres and Mista Lawnge sued UMG for breach of contract, breach of the implied covenant of good faith and fair dealing, and unjust enrichment. The duo claimed the label owed them and other artists roughly $750 million in unpaid royalties stemming from UMG’s deal with Spotify. But Judge Rochon said the two waited too long to bring their complaint.
“Under New York law, Plaintiffs must bring their claims for breach of contract and breach of the implied covenant of good faith and fair dealing within six years of the alleged breach,” the judge wrote. “Plaintiffs need not be aware of the breach to start the statute-of-limitations period.”
She continued, “Plaintiffs’ claims as to non-payment for a share of UMG’s Spotify stock are untimely. By Plaintiffs’ own admission, UMG’s first alleged breach of the contract occurred in or around 2008 when it failed to account for the value of its Spotify stock in its semiannual royalty statements. Plaintiffs’ claims accrued 15 years ago. Even accepting Plaintiffs’ alternative argument that UMG breached the contract again after Spotify’s IPO in 2018, Plaintiffs’ failure to bring those claims within two years of UMG’s alleged breach still renders them untimely.”
Judge Rochon’s ruling also diminished the merits of Black Sheep’s lawsuit. The judge said even if the claims were timely, “they would still fail as a matter of law.”
Dres of Black Sheep saw his lawsuit get dismissed the same week as the premiere of his new documentary The Choice Is Yours. The film is available to stream on Paramount Plus.