Statue of Lady Justice symbolizing jury verdicts and legal outcomes

Jury Awards 2 Live Crew Ownership Over Several Early Albums

BySwift Law, PA

Case: Lil’ Joe Records, Inc. v. Ross, Case No. 1:21-cv-23727 (S.D. Fla. filed Oct. 21, 2021)

In October 2024, a federal jury in Florida found in favor of 2 Live Crew (and heirs of deceased members) in a dispute with Lil’ Joe Records. The issue: decades ago, in bankruptcy proceedings, 2 Live Crew’s master recordings and publishing rights were sold to Lil’ Joe Records. In 2020, 2 Live Crew served a “termination notice” under U.S. Copyright Act § 203, which allows creators (or their heirs) to end transfers of copyrights after about 35 years, unless the work is “made for hire.” 2 Live Crew claimed their albums from the late 1980s were not works for hire and that their statutory rights to terminate remained valid even though the catalog was sold in bankruptcy.

Lil’ Joe countered that the works were works for hire, that the termination was voided by the bankruptcy, or that agreements were not properly in writing. The jury rejected those defenses, deciding that the albums were not works for hire and that 2 Live Crew satisfied the requirements for copyright termination. Therefore, they regained ownership over several of their early albums.

Lil’ Joe Records filed an appeal.

Why It Matters
  • Artists’ Rights to Reclaim Ownership: This case reaffirms that copyright termination rights under § 203 are real, and can survive prior actions, even bankruptcy sales. For creators, this shows that contracts and transfers long ago don’t always prevent getting rights back down the road.
  • Contract Drafting & Work-for-Hire Clarity: Whether something is a “work for hire” dramatically changes legal ownership. Businesses (labels, publishers, content companies) need very clear contracts, payment structures, and creative control documentation to prevent surprises where creators reclaim rights.
  • Risk & Uncertainty for IP Buyers, Investors: Entities that acquire catalogs, master rights, or IP in bankruptcy or otherwise could face future legal challenges. Valuations, licensing deals, or acquisitions should account for possible termination rights or challenges, which could affect revenue, ownership, or control.

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