Ramani v. Warner Music Group Corp

CourtDistrict Court, S.D. New York
DecidedJune 5, 2025
Docket1:24-cv-07445
StatusUnknown

This text of Ramani v. Warner Music Group Corp (Ramani v. Warner Music Group Corp) is published on Counsel Stack Legal Research, covering District Court, S.D. New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Ramani v. Warner Music Group Corp, (S.D.N.Y. 2025).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK VALMIKI RAMANI, Plaintiff, 24-CV-7445 (KMW) -against- ORDER OF DISMISSAL WARNER MUSIC GROUP CORP, WITH LEAVE TO REPLEAD Defendant. KIMBA M. WOOD, United States District Judge: Plaintiff, appearing pro se, brings this action against Defendant Warner Music Group Corporation (“WMG”), alleging that Defendant wrongfully obtained royalties from a music video that Plaintiff produced. By Order dated October 23, 2024, ECF No. 4, the Court granted Plaintiff’s request to proceed in forma pauperis (“IFP”), that is, without prepayment of fees.1 For the reasons set forth below, the Court dismisses this action for lack of subject matter jurisdiction and grants Plaintiff 30 days’ leave to file an amended complaint.

STANDARD OF REVIEW The Court must dismiss an IFP complaint, or any portion of the complaint, that is frivolous or malicious, fails to state a claim on which relief may be granted, or seeks monetary relief from a defendant who is immune from such relief. 28 U.S.C. § 1915(e)(2)(B); see Livingston v. Adirondack Beverage Co., 141 F.3d 434, 437 (2d Cir. 1998). The Court must also

1 Plaintiff has been barred under 28 U.S.C. § 1651 from filing any new civil action IFP in this court, without first obtaining permission from the court to file. See Ramani v. Haley, No. 24-CV-5747 (S.D.N.Y. Nov. 22, 2024) (Swain, C.J.), ECF No. 7. This injunction was issued after Plaintiff filed the instant action. dismiss a complaint when the Court lacks subject matter jurisdiction over the claims raised. See Fed. R. Civ. P. 12(h)(3). Although the law mandates dismissal on any of these grounds, the Court is obligated to construe pro se pleadings liberally, Harris v. Mills, 572 F.3d 66, 72 (2d Cir. 2009), and to interpret them to raise the “strongest [claims] that they suggest,” Triestman v. Fed. Bureau of

Prisons, 470 F.3d 471, 474 (2d Cir. 2006) (per curiam) (internal quotation marks and citations omitted) (emphasis in original). But the “special solicitude” courts provide to pro se litigants, id. at 475 (citation omitted), has its limits—to state a claim, pro se pleadings still must comply with Rule 8 of the Federal Rules of Civil Procedure, which requires a complaint to make a short and plain statement showing that the pleader is entitled to relief. Fed. R. Civ. P. 8(a)(2).

BACKGROUND The following facts are drawn from the complaint.2 On an unspecified date, Plaintiff, who writes and produces music videos, wrote the song “My Mystery Love,” which he “shot . . . in New York City.” (Compl., ECF 1 ¶¶ 1, 3.) Plaintiff “wanted an upbeat melody” for his song,

and after listening to “a rendition of Secret Love, [he] applied for a license to use the melody written by Sammy Fain,” which is “now owned by W.B. Music Corp.” (Id.) Because Plaintiff “paid for the right to use this melody, . . . the music video ‘My Mystery Love’ [is his] sole property.” (Id.) Plaintiff then uploaded the music video for “My Mystery Love” onto his “channel on Facebook.” (Id. ¶ 4.) Facebook permitted the song video to be played because “[Plaintiff] had

2 The Court quotes verbatim from the complaint. All spelling, grammar, and punctuation appear as in the complaint, unless noted otherwise. bought 100 digital downloads [of “Secret Love”]. Facebook never ha[d] . . . permission” to obtain royalties from the video. (Id.) Recently, however, Plaintiff learned that Defendant was wrongfully obtaining royalties from his music video because the video features a song that uses the “Secret Love” melody owned by Defendant. (Id. ¶ 5.) Plaintiff had paid a licensing fee to use this melody. (Id.)

Defendant “monetize[d] [the] video world wide and gave [Plaintiff] 20% of the income.” (Id. ¶ 6.) Plaintiff contends that Defendant “has no right to take [his] property and exploit it without first getting [his] permission.” (Id. ¶ 7.) He further contends that Defendant has “no ownership in whole or part of [the] video” and that he “paid them to use the melody of Secret Love.” (Id.) Plaintiff claims that Defendant stole his property and “illegally exploited it for financial gain,” asserting that it is “guilty of theft.” (Id.) He seeks $500,000 in money damages.

DISCUSSION A. The Court lacks subject matter jurisdiction over Plaintiff’s claims The subject matter jurisdiction of the federal district courts is limited and is set forth in 28 U.S.C. §§ 1331 and 1332. Under these statutes, a federal district court has jurisdiction only

when a “federal question” is presented, or when plaintiff and defendant are citizens of different states and the amount in controversy exceeds the sum or value of $75,000. “[I]t is common ground that in our federal system of limited jurisdiction any party or the court sua sponte, at any stage of the proceedings, may raise the question of whether the court has subject matter jurisdiction.” United Food & Com. Workers Union, Loc. 919, AFL–CIO v. CenterMark Props. Meriden Square, Inc., 30 F.3d 298, 301 (2d Cir. 1994) (quoting Manway Constr. Co. v. Hous. Auth. of the City of Hartford, 711 F.2d 501, 503 (2d Cir. 1983)) (emphasis added); see Fed. R. Civ. P. 12(h)(3) (“If the court determines at any time that it lacks subject-matter jurisdiction, the court must dismiss the action.”); Ruhrgas AG v. Marathon Oil Co., 526 U.S. 574, 583 (1999) (“[S]ubject-matter delineations must be policed by the courts on their own initiative[.]”). Federal question jurisdiction To invoke federal question jurisdiction, aplaintiff’s claims must arise “under the Constitution, laws, or treaties of the United States.” 28 U.S.C. § 1331. A case arises under

federal law if the complaint “establishes either that federal law creates the cause of action or that the plaintiff’s right to relief necessarily depends on resolution of a substantial question of federal law.” Bay Shore Union Free Sch. Dist. v. Kain, 485 F.3d 730, 734-35 (2d Cir. 2007)(quoting Empire Healthchoice Assurance, Inc. v. McVeigh, 547 U.S. 677, 690 (2006)). Mere invocation of federal jurisdiction, without any facts demonstrating a federal law claim, does not create federal subject matter jurisdiction. See Nowak v.

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Ramani v. Warner Music Group Corp, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ramani-v-warner-music-group-corp-nysd-2025.