Artist News Business News Legal Management & Funding Top Stories

Court cuts back legal claims against Chance The Rapper by former manager

By Chris Cooke | Published on Friday 16 July 2021

An Illinois state court yesterday cut back the lawsuit filed against Chance The Rapper by his former manager Pat Corcoran, leaving just one claim over unpaid commissions. Meanwhile, the rapper’s countersuit, accusing his ex-manager of breaching his fiduciary duty to his former client, will proceed.

Corcoran sued the rapper, real name Chancelor Bennett, late last year. His lawsuit described in some detail Corcoran’s long-term partnership with Bennett, claiming that the rapper had ultimately started ignoring his advice resulting in a lacklustre album and cancelled tour. Bennett then blamed Corcoran for the downturn his career had taken and sacked his manager in April 2020.

The legal filing accused Bennett of breach of contract, unjust enrichment and violation of the Illinois Sales Representative Act, and sought payment of monies Corcoran reckoned he was owed from his time working with the rapper, which topped $3 million.

Bennett quickly hit back, insisting his ex-manager had been paid everything he was owed, while adding that Corcoran’s lawsuit was full of “self-serving and fabricated allegations”. A legal filing then followed in February this year which formally disputed all of Corcoran’s allegations, before making a few allegations of its own accusing the manager of bad conduct.

The key allegation against Corcoran was that, unbeknownst to Bennett, he had repeatedly traded off his client’s good name and career success in order to benefit his other business interests.

As an example, the countersuit alleged that when Live Nation approached Corcoran about working with Bennett, the manager used the resulting meeting to promote a wine company he was involved in to the live music giant. Similar self serving behaviour by the manager, it’s alleged, cost the rapper a partnership with the music company UnitedMasters.

Beyond the different versions of how the Bennett/Corcoran partnership worked – and who was responsible for the disappointing performance of the rapper’s first album – at the core of this dispute is the deal that was done between the artist and the manager. Though, unfortunately, that management deal was an oral agreement, which is always fun when people fall out and end up in court.

Corcoran would like to enforce a ‘sunset clause’ on his former client, a common feature of a formal management deal that allows a manager to continue commissioning even once they are no longer working for an artist. Meanwhile Bennett’s claims partly rely on the idea that his contractural relationship with Corcoran implied a fiduciary duty that the manager might have breached.

In yesterday’s hearing, the judge rejected most of Corcoran’s claims, beyond the dispute over unpaid commissions, although the manager was given the option to amend and resubmit his claims under the Illinois Sales Representative Act.

Meanwhile, Bennett’s claims against Corcoran were able to proceed. According to Law360, Corcoran argued that his former client’s lawsuit failed to show that the two men had the kind of ‘principal-agent relationship’ that would result in him having a fiduciary duty to the rapper, but the judge did not concur. She reckoned that claims in Bennett’s lawsuit did suggest a ‘principal-agent relationship’ even if it wasn’t explicitly stated.

And so the case continues, albeit significantly stripped back when it comes to Corcoran’s claims.