The Legal Beat: Megan Thee Stallion Defeats Summary Judgment Motion

There has been a new ruling in favor of Megan Thee Stallion (real name Megan Pete) in her lawsuit against her record label, 1501 Certified Entertainment (“1501”). In early 2022 Megan sued 1501 alleging that it mischaracterized her most recent 2021 album (Something For the Hotties) as a mixtape rather than an album.

 This is an important distinction, because if it was a mixtape it does not go toward satisfying the “minimum recording commitment” in Pete’s recording contract and thus she would owe 1501 another album. Once an artist fulfills his or her minimum recording commitment, they are free to seek a new deal (and a new advance) with a different label.

1501 filed a motion for partial summary judgment seeking a pre-trial ruling that, as a matter of law, Pete’s 2021 album was something less than an album. In December of 2022 a judge in Texas ruled in Pete’s favor on 1501’s motion. This ruling means that the case can now proceed to trial where all issues will be decided. In her successful opposition papers, Pete stated:

“Pete should be allowed her day in court to present evidence and testimony to the jury demonstrating that she has done all that was required of her in the delivery and release of her albums.”

1501 contended that freestyles, monologues and skits that were included on the album in question do not constitute new music which would be applied to satisfy her minimum recording commitment. Pete argued in her opposition papers that such previously published content does constitute new music because, notwithstanding the fact that they may have appeared on YouTube, they were never released to the public in a format that was commercially distributed. It will be interesting to see how these issues are decided in a trial, unless, of course, the case settles.

By way of background, a motion for summary judgment is a motion where the moving party alleges that there are no issues of fact for a judge or jury to decide and the moving party is entitled to judgment as a matter of law without the need for a trial.  A motion for partial summary judgment is a motion that disposes of some of the causes of action, but not the entire case.  

A motion for summary judgment is intended to resolve cases without a trial where the relevant facts are not in dispute and the moving party is entitled to a judgment (or partial judgment) as a matter of law.  In general, before a court will grant a summary judgment and deny a party the important right to a trial, the facts must be very clear. If a summary judgment is granted, it saves the parties and the court the time and expense of a trial. To defeat a summary judgment motion the opposing party must prove that there are triable issues of fact.

When a party files a motion for summary judgment, declarations are usually attached as well as points and authorities (a brief) in support of the motion. The party opposing the motion can then file declarations that contest the moving party’s allegations.