Decision of Note: <b>Copyright Law Preempts Claims Against Kid Rock</b>

The U.S. Court of Appeals for the Sixth Circuit ruled that the majority of state law claims against Kid Rock over music contracts the artist signed early in his career were preempted by federal copyright law. Ritchie v. Williams, 03-1279.

In its ruling, the Sixth Circuit embraced the U.S. Supreme Court's complete preemption doctrine which “recharacterize[s] a state law claim … as an action arising under federal law” and “converts an ordinary state common law complaint into one stating a federal claim for purposes of the well-pleaded complaint rule.” Metropolitan Life Ins. Co. v. Taylor, 481 U.S. 58 (1987).

The Second and Fourth Circuits are the only circuits to have previously used the complete-preemption doctrine in copyright cases. See, Briarpatch Ltd. v. Phoenix Pictures Inc., 373 F.3d 296 (2d Cir. 2004); Rosciszewski v. Arete Assocs., 1 F.3d 225 (4th Cir. 1993).

The plaintiffs in Ritchie claimed that Kid Rock violated his 1989 agreements with them by soon after signing deals with other companies for the same rights. The preempted claims include for unjust enrichment, misrepresentation, conversion and injunctive relief against further misappropriation. The appeals court also ruled the preempted claims were barred by the 3-year statute of limitations of the Copyright Act. Two non-preempted claims ' for breach of fiduciary duty and breach of contract ' were found time-barred under Michigan law.

The U.S. Court of Appeals for the Sixth Circuit ruled that the majority of state law claims against Kid Rock over music contracts the artist signed early in his career were preempted by federal copyright law. Ritchie v. Williams, 03-1279.

In its ruling, the Sixth Circuit embraced the U.S. Supreme Court's complete preemption doctrine which “recharacterize[s] a state law claim … as an action arising under federal law” and “converts an ordinary state common law complaint into one stating a federal claim for purposes of the well-pleaded complaint rule.” Metropolitan Life Ins. Co. v. Taylor , 481 U.S. 58 (1987).

The Second and Fourth Circuits are the only circuits to have previously used the complete-preemption doctrine in copyright cases. See , Briarpatch Ltd. v. Phoenix Pictures Inc. , 373 F.3d 296 (2d Cir. 2004); Rosciszewski v. Arete Assocs. , 1 F.3d 225 (4th Cir. 1993).

The plaintiffs in Ritchie claimed that Kid Rock violated his 1989 agreements with them by soon after signing deals with other companies for the same rights. The preempted claims include for unjust enrichment, misrepresentation, conversion and injunctive relief against further misappropriation. The appeals court also ruled the preempted claims were barred by the 3-year statute of limitations of the Copyright Act. Two non-preempted claims ' for breach of fiduciary duty and breach of contract ' were found time-barred under Michigan law.