April 24, 2015 | News

Firm succeeds in Eleventh Circuit by obtaining ruling affirming dismissal of all but one of stylist's claims against A-list hip-hop artist

Jonathan D. Davis, P.C. represented a famous hip-hop artist and her company in a lawsuit filed by the artist's former stylist in Georgia federal court. The claims principally involved alleged ventures to develop a wig line and a reality television show. We successfully moved to dismiss all of the claims. An appeal was taken for some of the dismissed claims. The Eleventh Circuit Court of Appeals affirmed the District Court's dismissal of the claims for unjust enrichment and promissory estoppel. It also affirmed the denial of plaintiff's request to amend the complaint a second time. The Court left standing plaintiff's quantum meruit claim, which sought recovery of the reasonable value of plaintiff's services that were attributable to the purported "commercial-use" of his alleged wig designs. Accepting the allegations in the light most favorable to plaintiff, as is required at the motion to dismiss stage, the Court ruled that it was possible to infer from plaintiff's pleading that he was entitled to additional compensation under an implied-in-fact agreement with the artist. However, the Court observed that "the service rendered – the design of the wigs – is, in a sense, the same whether [artist] kept the wigs for her personal use or decided to market them commercially," and that the "actual reasonable value of [plaintiff's] services remains a matter of proof," which may ultimately be determined to be no greater than what the artist already paid plaintiff.

The Court's decision is available here.