Booth v. Anschutz Entertainment Group, INC

CourtDistrict Court, N.D. Texas
DecidedFebruary 3, 2025
Docket3:24-cv-00194
StatusUnknown

This text of Booth v. Anschutz Entertainment Group, INC (Booth v. Anschutz Entertainment Group, INC) is published on Counsel Stack Legal Research, covering District Court, N.D. Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Booth v. Anschutz Entertainment Group, INC, (N.D. Tex. 2025).

Opinion

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF TEXAS DALLAS DIVISION

TIMOTHY CABE BOOTH, § § Plaintiff, § § v. § Civil Action No. 3:24-CV-0194-X § Consolidated with Civil Action No. ANSCHUTZ ENTERTAINMENT § 3:24-cv-0269 GROUP, INC., et al., § § Defendants. §

MEMORANDUM OPINION AND ORDER There are two motions to dismiss pending in this consolidated case: (1) Defendant AEG Presents, LLC’s (AEG) Motion to Dismiss John Freeman Booth, Jr.’s lawsuit (Doc. 11),1 and (2) Defendants Anschutz Entertainment Group, Inc., AEG Live, LLC, Anschutz Texas, LP, AEG Presents, LLC, and Robin Phillips’s (Defendants)2 Motion to Dismiss Plaintiff Timothy Cabe Booth’s First Amended Complaint (Doc. 40). After reviewing the motions, briefing, and applicable law, the Court DENIES AEG’s Motion to Dismiss John Booth’s lawsuit (Doc. 11), and GRANTS IN PART and DENIES IN PART Defendants’ Motion to Dismiss Timothy Cabe Booth’s First Amended Complaint (Doc. 40). The Court grants leave to Plaintiff Timothy Cabe Booth (Cabe Booth) to file one final amended complaint within twenty- eight (28) days from the date of this order.

1 Doc. 11 in member case, Case No. 3:24-cv-0269-X. 2 Robin Phillips was dismissed as a defendant subsequent to the filing of this Motion. (Doc. 53). I. Factual Background Artists and brothers Cabe Booth and John Freeman Booth, Jr. (together, Artists), brought individual suits against the Defendants, asserting claims under the Visual Artists Rights Act (the Act); the Court consolidated their cases. The artists

produced performer portraits for the Texas Trust CU Theatre in Grand Prairie (Theatre). The Defendants3 leased and operated the Theatre, which the City of Grand Prairie owns. The Artists bring suit alleging violations of the Act for portraits in the Defendants’ possession that may have been destroyed, damaged, or disposed of, allegedly following the 2021 Winter Freeze, a remodel, or both. The Defendants filed two separate motions, prior to consolidation, to dismiss each lawsuit. The Court

resolves them both here. II. Legal Standard The Federal Rules require a pleading to contain “a short and plain statement of the claim showing that the pleader is entitled to relief.”4 A Rule 12(b)(6) motion challenges such a pleading for a “failure to state a claim upon which relief can be granted.”5 When analyzing the pleadings under a Rule 12(b)(6) motion, the complaint must contain “only enough facts to state a claim to relief that is plausible on its face.”6

“A claim has facial plausibility when the plaintiff pleads factual content that allows the court to draw the reasonable inference that the defendant is liable for the

3 AEG employs Defendant Phillips. 4 Fed. R. Civ. P. 8(a)(2). 5 Fed. R. Civ. P. 12(b)(6). 6 Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 570 (2007). misconduct alleged.”7 However, the recitation of facts must move the “claims across the line from conceivable to plausible.”8 In reviewing a complaint, the Court “accepts all well-pleaded facts as true and draws all reasonable inferences in favor of the nonmoving party.”9 However, there are a number of categories that the Court does

not presume to be true, including “legal conclusions; mere labels; threadbare recitals of the elements of a cause of action; conclusory statements; and naked assertions devoid of further factual enhancement.”10 III. Analysis A. AEG Presents, LLC’s Motion to Dismiss (Doc. 11)11 AEG argues that John Booth’s complaint fails to identify works of art subject to

protections under the Act, instead arguing the disposed pieces are posters, and that John Booth misunderstands the events giving rise to the disposal of the items in question—that they were damaged in the winter storm of February 2021. John Booth argues that these are questions of fact that are improper for a Rule 12(b)(6) motion, and that he has met his pleading burden. The Court agrees that John Booth has sufficiently pled his claims under the Act. Section 106A of the Act provides that “the author of a work of visual art” shall

have the right of attribution and the right of integrity.12 The Act conveys the right for

7 Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009). 8 Twombly, 550 U.S. at 570. 9 Harmon v. City of Arlington, Texas, 16 F.4th 1159, 1162 (5th Cir. 2021) (cleaned up). 10 Id. at 1162–63. 11 All docket citations pertaining to this motion are to the member case: Case No. 3:24-cv-0269. 12 17 U.S.C. § 106A(a). said author to prevent the distortion, destruction, or modification of protected works.13 A “work of visual art” includes “a painting, drawing, print, or sculpture, existing in a single copy, [or] in a limited edition of 200 copies or fewer,” but excludes, among other things, “any poster[;] . . . any merchandising item or advertising, promotional[;] . . . [or]

any work made for hire.”14 John Booth’s Complaint alleges he sold hand painted portraits of artists and performers to the Texas Trust CU Theatre at Grand Prairie, leased by AEG. AEG also admits these portraits were produced “in a painted or photographic format.”15 Whether or not the performer portraits are or are not a painting is a fact issue. However, John Booth does not identify a specific portrait or portraits that were

destroyed. John Booth does provide a list of forty-six (46) portraits, and he alleges he provided over forty (40) to AEG between 2007 and 2010.16 AEG argues that John Booth’s claim must fail for this lack of specificity. AEG’s own inventory list does not specify which portraits, labeled as “Wooden Artwork” were damaged.17 To survive a Rule 12(b)(6) motion to dismiss, a complaint does not need to contain detailed factual allegations, but “must be enough to raise a right to relief above the speculative level.”18 As John Booth cannot know what portraits were destroyed from his vantage point, but

has identified which artwork he provided to AEG, the Court finds this sufficient to raise

13 Id. § 106A(a)(3). 14 Id. § 101. 15 Doc. 11 ¶ 2.3. 16 Doc. 1, App. A. 17 Doc. 11 ¶ 2.5; Doc. 11-1 at 7. 18 Twombly, 550 U.S. at 555. his right to relief under the Act above the speculative level. Next, the Complaint alleges that Defendants “disposed of” some of the portraits “in a dumpster.”19 Section 106A(a)(3) states: [T]he author of a work of visual art . . . subject to the limitations set forth in section 113(d), shall have the right—

(A) to prevent any intentional distortion, mutilation, or other modification of that work which would be prejudicial to his or her honor or reputation, and any intentional distortion, mutilation, or modification of that work is a violation of that right, and

(B) to prevent any destruction of a work of recognized stature, and any intentional or grossly negligent destruction of that work is a violation of that right.20 At this stage, the Court accepts well-pled facts as true and draws all reasonable inferences in favor of Booth.21 Thus, if AEG disposed of some portraits in a dumpster, a reasonable inference would be that AEG is liable for distortion or destruction under the Act. AEG’s arguments as to the facts of the case are not proper at this stage. Because the Court finds that John Booth has sufficiently pled facts giving rise to relief, AEG’s motion to dismiss is DENIED. B. Motion to Dismiss Cabe Booth’s First Amended Complaint (Doc.

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Related

Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Castillo v. G&M Realty L.P.
950 F.3d 155 (Second Circuit, 2020)
Harmon v. City of Arlington
16 F.4th 1159 (Fifth Circuit, 2021)

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