Joseph Roderick Jr. v. William Martin Joel, AKA “Billy Joel”; Sony Music Entertainment/Columbia Records; Liberty Devitto; Dennis Alexander

District Court, D. Arizona·Decided January 13, 2026·No. 2:26-cv-00594·Unknown

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK JOSEPH RODERICK JR., Plaintiff, -against- 25-CV-5446 (LLS) WILLIAM MARTIN JOEL, AKA “BILLY SECOND ORDER OF DISMISSAL JOEL”; SONY MUSIC AND TRANSFER ORDER ENTERTAINMENT/COLUMBIA RECORDS; LIBERTY DEVITTO; DENNIS ALEXANDER, Defendants. LOUIS L. STANTON, United States District Judge: Plaintiff, who is proceeding pro se and in forma pauperis (“IFP”), filed the original complaint in this action alleging that Defendants violated his rights under the Copyright Act and under state law. By order dated September 3, 2025, the Court directed Plaintiff to amend his complaint to address deficiencies in his original pleading. Plaintiff filed an amended complaint on October 3, 2025, and the Court has reviewed it. For the reasons set forth below, the Court dismisses Plaintiff’s federal copyright claims without prejudice and transfers his claims under state law to the United States District Court for the District of Arizona. BACKGROUND Plaintiff brings this action against William Martin Joel, professionally known as Billy Joel, Sony Music Entertainment/Columbia Records (“Sony Music”), Liberty Devitto, and Dennis Alexander. In the original complaint, Plaintiff asserted claims of federal copyright infringement as well as claims under state law arising from his allegedly having recorded drum tracks in 1979 that were included in Joel’s 1980 song “You May Be Right.” In its September 3, 2025 order, the Court dismissed Plaintiff’s federal copyright claims because he did not allege that he had registered the work in question with the United States Copyright Office (“USCO”). (ECF 5, at 4- 5.) The Court further held that Plaintiff did not allege facts demonstrating that the Court had diversity jurisdiction to consider his state law claims, and it declined to exercise supplemental jurisdiction of those claims under 28 U.S.C. § 1367(c)(3). (Id. at 5-8.) The Court also noted that it was unclear from the complaint where Plaintiff’s state law claims arose, and, therefore, it was

unclear whether this district was a proper venue for such claims. The Court directed Plaintiff, should he replead his state law claims, to allege facts demonstrating that venue for such claims is proper in this court. (Id. at 7 n. 3.) In its order, the Court also noted that Plaintiff had previously filed a similar complaint against Joel, Devitto, Sony Music, and Alexander in the United States District Court for the District of Arizona. See Roderick v. Joel, No. 2:24-CV-1871 (SMB) (D. Ariz. Dec. 20, 2024). By order dated October 30, 2024, that court dismissed as untimely Plaintiff’s state law claims for breach of contract, detrimental reliance, fraudulent and negligent misrepresentation, and negligent and intentional infliction of emotional distress. Id., ECF 26. After granting Plaintiff several opportunities to amend his federal copyright infringement claims, by order dated

December 20, 2024, the court dismissed the third amended complaint for failure to state a claim on which relief may be granted. Id., ECF 37. The court held that, despite instructing Plaintiff on the need to register his copyright before bringing a federal copyright infringement action, Plaintiff’s allegations did not demonstrate that he complied with the registration requirement. Even though “[that] deficiency alone require[d] dismissal” of Plaintiff’s copyright claims, the court also discussed why Plaintiff’s allegations were deficient, including its finding that Plaintiff “simply has not pleaded that he owns a valid copyright of the song ‘You May Be Right.’” Id. at 3. The court dismissed the action without prejudice. The following facts are drawn from the amended complaint.1 Between April and November 1979, Plaintiff was invited by a keyboardist named Brian Shackleford to participate in a record session for Defendant Dennis Alexander at Pantheon Recording in Scottsdale, Arizona. Plaintiff recorded three songs and “received a $50.00 check for his services.” (ECF 6, at 3.)

During the recording session, Plaintiff “composed and performed all drum arrangements for ‘You May Be Right,’ meticulously developing the intro, transition, verses, breaks, and chorus.” (Id.) Plaintiff was given “[n]o instructions” on what or how to play, and “[p]ayment was received on the day of the session.” (Id.) Approximately two weeks after the recording session, Shackleford informed Plaintiff that Joel “had selected two songs from the session and promised that Plaintiff would be compensated ‘on the other end.’” (Id.) Plaintiff alleges that he suffered from mental health issues between 1980 and 1985, and only “recognized his involvement in ‘You May Be Right’” after hearing the song on the radio in 2018 or 2019. (Id.) He contacted Shackleford in 2019 and emailed Alexander in 2023, but he has not received any compensation “beyond the initial payment.” (Id.)

Plaintiff did not “realize[] the potential to pursue legal action” against Defendants until 2023. (Id.) Plaintiff further alleges that Devitto filed a complaint in 2009 for unpaid royalties and breach of contract, and has since been credited for playing drums on “You May Be Right’ and has been “compensated accordingly.” (Id. at 4.) With respect to registering his copyright with the USCO, Plaintiff alleges that he “filed copyright registration in July 2024 (file#1-14410612761).” (Id.) He does not allege what specific

1 The Court quotes from the amended complaint verbatim. All spelling, grammar, and punctuation are as in the amended complaint unless noted otherwise. work or works he registered, but he states that the “sound recording registration is currently active.” (Id.) With respect to diversity jurisdiction, Plaintiff, who is a resident of the State of Ohio, alleges that Sony Music maintains its headquarters in New York, New York, and Defendant

Devitto resides in Brooklyn, New York. He further alleges that Joel resides in Florida, and that Alexander was a “resident of Arizona at the time of the incident and currently.” (Id. at 2.) DISCUSSION A. Claims for copyright infringement To state a claim for copyright infringement, a plaintiff must allege both (1) ownership of a valid copyright and (2) infringement of the copyright by the defendant. Spinelli v. Nat’l Football League, 903 F.3d 185, 197 (2d Cir. 2018) (citation omitted). The registration of a plaintiff’s copyright with the United States Copyright Office is not required for a work to obtain copyright protection. See 17 U.S.C. § 408(a) (“[R]egistration is not a condition of copyright protection.”). Nevertheless, registration of a copyright with the USCO is a precondition for bringing a copyright infringement action in federal court. See 17 U.S.C. § 411(a) (“[N]o civil

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Joseph Roderick Jr. v. William Martin Joel, AKA “Billy Joel”; Sony Music Entertainment/Columbia Records; Liberty Devitto; Dennis Alexander, (D. Ariz. 2026).

Joseph Roderick Jr. v. William Martin Joel, AKA “Billy Joel”; Sony Music Entertainment/Columbia Records; Liberty Devitto; Dennis Alexander (Joseph Roderick Jr. v. William Martin Joel, AKA “Billy Joel”; Sony Music Entertainment/Columbia Records; Liberty Devitto; Dennis Alexander) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

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