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Keywords

contractbreach of contractplaintiffinjunctionappealtrial

contractplaintiffdefendantinjunction

Related Cases

Beverly Glen Music, Inc. v. Warner Communications, Inc., 178 Cal.App.3d 1142, 224 Cal.Rptr. 260

Facts

In 1982, Beverly Glen Music, Inc. signed a contract with singer Anita Baker, who recorded a moderately successful album. In 1984, Baker accepted a better offer from Warner Communications and notified Beverly Glen that she would no longer perform under her contract. Beverly Glen then sued Baker to prevent her from performing for any other studio, but the injunction was denied. Subsequently, Beverly Glen sued Warner Communications for inducing Baker's breach of contract and sought an injunction against Warner.

In 1982, plaintiff Beverly Glen Music, Inc. signed to a contract a then-unknown singer, Anita Baker. Ms. Baker recorded an album for Beverly Glen which was moderately successful, grossing over one million dollars. In 1984, however, Ms. Baker was offered a considerably better deal by defendant Warner Communications.

Issue

Whether Beverly Glen Music, Inc. could obtain a preliminary injunction against Warner Communications to prevent them from employing Anita Baker, who had breached her contract with Beverly Glen.

The sole issue before us then is whether plaintiff—although prohibited from enjoining Ms. Baker from performing herself—can seek to enjoin all those who might employ her and prevent them from doing so, thus achieving the same effect.

Rule

California law prohibits the granting of an injunction to prevent the breach of a personal service contract unless the service is unique and the performer is guaranteed annual compensation of at least $6,000.

These sections both provided that an injunction could not be granted: 'To prevent the breach of a contract the performance of which would not be specifically enforced.'

Analysis

The court applied the rule by determining that Beverly Glen could not enjoin Warner Communications from employing Baker, as doing so would effectively deprive Baker of her livelihood and pressure her to return to Beverly Glen. The court noted that the intent behind the plaintiff's action was the same whether directed at Baker or Warner, which was to coerce Baker into honoring her contract. The court emphasized that the legislature had forbidden such remedies except in very limited circumstances.

Whether plaintiff proceeds against Ms. Baker directly or against those who might employ her, the intent is the same: to deprive Ms. Baker of her livelihood and thereby pressure her to return to plaintiff's employ.

Conclusion

The Court of Appeal affirmed the trial court's order denying the injunction, concluding that Beverly Glen Music, Inc. could not achieve the same effect of coercing Baker through an injunction against her new employer.

We therefore decline to reverse the order.

Who won?

Warner Communications prevailed in the case because the court found that the injunction sought by Beverly Glen was not permissible under California law, which prohibits such actions against new employers.

The order is affirmed.

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