Angela Reliford v. Sony Music Entertainment, Inc., et al.

CourtDistrict Court, D. Nevada
DecidedFebruary 10, 2026
Docket2:25-cv-01088
StatusUnknown

This text of Angela Reliford v. Sony Music Entertainment, Inc., et al. (Angela Reliford v. Sony Music Entertainment, Inc., et al.) is published on Counsel Stack Legal Research, covering District Court, D. Nevada primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Angela Reliford v. Sony Music Entertainment, Inc., et al., (D. Nev. 2026).

Opinion

1 UNITED STATES DISTRICT COURT

2 DISTRICT OF NEVADA

3 ANGELA RELIFORD, 4 Plaintiff, Case No.: 2:25-cv-01088-GMN-BNW 5 vs. ORDER GRANTING MOTION TO 6 SONY MUSIC ENTERTAINMENT, INC., et DISMISS AND STAYING CASE 7 al.,

8 Defendants.

9 10 Pending before the Court is the Motion to Dismiss, (ECF No. 24), filed by Defendant 11 Sony Music Entertainment (“SME”).1 Plaintiff Angela Reliford filed a Response, (ECF No. 12 39), to which SME filed a Reply, (ECF No. 51).2 Also before the Court are the parties’ 13 Responses, (ECF Nos. 108, 110), to the Court’s Order to Show Cause, (ECF No. 107), ordering 14 the parties to show cause why this Court should not stay or dismiss this action under the 15 doctrine articulated in Colorado River Water Conversation District v. United States, 424 U.S. 16 800 (1976). Further pending before the Court is Plaintiff’s Motion to Remand, (ECF No. 9), to 17 which SME filed a Response, (ECF No. 37), and Plaintiff filed a Reply, (ECF No. 55). Also 18 19

20 1 Plaintiff’s Complaint also names Defendants RCA Records and Christoper M. Brown. RCA Records is a 21 division of SME, not a separate entity. (Mot. Dismiss 1:19, ECF No. 24). SME’s Motion to Dismiss therefore applies to all claims asserted against both SME and RCA Records, who is erroneously sued as a separate entity. 22 2 Plaintiff also filed the pending Motion for Leave to File Supplemental Opposition to Defendant’s Motion to Dismiss, (ECF No. 52). In her Motion, Plaintiff essentially seeks leave to file a surreply. Per Local Rule 7-2, 23 “motions for leave to file a surreply are discouraged.” Generally, surreplies are permitted where new arguments were raised in the Reply. That is not the case here. Plaintiff was given an opportunity to respond to SME’s 24 arguments in her Response and makes no showing of why she was unable to make the arguments included in the proposed surreply in her original Response. The information did not become available only after the filing of 25 SME’s Reply; rather, it appears Plaintiff merely seeks another opportunity to rebut SME’s arguments. Such an opportunity is not provided for in the Federal Rules of Civil Procedure or this Court’s Local Rules. Accordingly, the Court DENIES Plaintiff’s Motion for Leave to File Supplemental Opposition. 1 pending before the Court are Plaintiff’s Motion for Default Judgment, (ECF No. 28),3 Motion 2 for Consideration of Plaintiff’s Statement Regarding Jurisdictional Harm, (ECF No. 46), 3 Motion to Stay Discovery, (ECF No. 45),4 Motion for Leave to File Revised Proposed Second 4 Amended Complaint, (ECF No. 88), and Motion for Court Ordered Alternative Service, (ECF 5 No. 103). Lastly, SME’s Motion to Stay Discovery, (ECF No. 45), is also pending before the 6 Court. 7 Because the Court finds that it does not have personal jurisdiction over SME, and stays 8 this case under the Colorado River abstention doctrine, the Court GRANTS SME’s Motion to 9 Dismiss and DENIES the remaining motions as moot.5 10 I. BACKGROUND 11 This case arises out of Defendant Chris Brown’s alleged posting of a defamatory post 12 about Plaintiff. (Compl., Ex. 2 to Pet. Removal, ECF No. 1-2). Plaintiff is an aspiring actress 13 and content creator. (Id. ¶ 1). Plaintiff alleges that Brown posted a video on Instagram that 14 used a manipulated version of Plaintiff’s original video and falsely depicted her as a violent and 15 mentally unstable individual. (Id. at 3). The post reached over 145 million followers, which 16 Plaintiff avers incited harassment, ridicule, workplace hostility, and physical assault against 17 her. (Id.). Plaintiff claims that SME and RCA Records, who exercise control over Brown’s

18 branding and public activity, failed to intervene when Brown posted the video. (Id. ¶ 12). She 19 asserts the following claims for relief: (1) Defamation/Slander; (2) False Light; (3) Libel; (4) 20

21 22 3 Also pending before the Court is the Report and Recommendation issued by Magistrate Judge Weksler, (ECF No. 79). Because the Court denies the Motion for Default Judgment as moot, it also rejects the Report and 23 Recommendation as moot. 4 Plaintiff also filed the pending Motion for Leave to File Sur-Reply to the Motion to Stay Discovery, (ECF No. 24 70). Because the Court denies the Motion to Stay Discovery as moot, it also Plaintiff’s Motion for Leave to File Sur-Reply as moot. 25 5 Plaintiff’s Motion for Leave to File Revised Proposed Second Amended Complaint, (ECF No. 88), and Motion for Court Ordered Alternative Service, (ECF No. 103), are denied without prejudice, with leave to refile after this case is unstayed in the event the state court litigation does not resolve all issues in this case. 1 Intentional Infliction of Emotional Distress; (5) Negligent Infliction of Emotional Distress; and 2 (6) Negligence. (Id. at 7). 3 Plaintiff originally filed this case in the Eighth Judicial District Court of Clark County, 4 Nevada on January 21, 2025. (Pet. Removal 1:23–25, ECF No. 1). SME removed the case to 5 this Court on June 18, 2025. (Id.). Plaintiff then filed the instant Motion to Remand, and SME 6 filed the instant Motion to Dismiss asserting that the Court lacks personal jurisdiction over 7 SME and that Plaintiff failed to state a claim against it. In response to SME’s filing of a Notice 8 of Related Cases, (ECF No. 104), the Court entered an Order to Show Cause in writing why 9 this Court should not stay or dismiss this action under the Colorado River doctrine. The parties 10 both filed a Response, (ECF Nos. 108, 110), and this Order follows. 11 II. LEGAL STANDARD 12 A. Motion to Dismiss for Lack of Personal Jurisdiction 13 Federal Rule of Civil Procedure (“FRCP”) 12(b)(2) permits a defendant, by way of 14 motion, to assert the defense that a court lacks personal jurisdiction over a defendant. Fed. R. 15 Civ. P. 12(b)(2). The party asserting the existence of jurisdiction bears the burden of 16 establishing it. See Mattel, Inc. v. Greiner & Hausser GmbH, 354 F.3d 857, 862 (9th Cir. 17 2003). When a 12(b)(2) motion is based on written materials, rather than an evidentiary

18 hearing, a “plaintiff need make only a prima facie showing of jurisdictional facts to withstand 19 the motion to dismiss.” Ballard v. Savage, 65 F.3d 1495, 1498 (9th Cir. 1995). “This prima 20 facie standard ‘is not toothless,’ however; [plaintiff] ‘cannot simply rest on the bare allegations 21 of its complaint.’” AMA Multimedia, LLC v. Wanat, 970 F.3d 1201, 1207 (9th Cir. 2020) 22 (quoting In re Boon Glob. Ltd., 923 F.3d 643, 650 (9th Cir. 2019)), overruled in part on other 23 grounds by Briskin v. Shopify, Inc., 135 F.4th 739 (9th Cir. 2025). 24 In reviewing a motion, the court accepts “as true all uncontroverted allegations in the 25 complaint.” Glob. Commodities Trading Grp., Inc. v. Beneficio de Arroz Choloma, S.A., 972 1 F.3d 1101, 1106 (9th Cir. 2020). If the defendant comes forward with a “contradictory 2 affidavit, the plaintiff cannot simply rest on the bare allegations of its complaint.” Yamashita v. 3 LG Chem, Ltd., 62 F.4th 496, 502 (9th Cir. 2023) (internal citation and quotations omitted). 4 However, “[i]f both sides submit affidavits, then ‘[c]onflicts between the parties over 5 statements contained in affidavits must be resolved in the plaintiff’s favor.’” LNS Enters. LLC 6 v. Cont’l Motors, Inc., 22 F.4th 852, 858 (9th Cir. 2022) (quoting Boschetto v. Hansing, 539 7 F.3d 1011, 1015 (9th Cir. 2008). 8 When no federal statute applies to the determination of personal jurisdiction, the law of 9 the state in which the district court sits applies. Schwarzenegger v.

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Angela Reliford v. Sony Music Entertainment, Inc., et al., Counsel Stack Legal Research, https://law.counselstack.com/opinion/angela-reliford-v-sony-music-entertainment-inc-et-al-nvd-2026.