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Sample Case Study Paper on Case: Parks v. LaFace Records

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Sample Case Study Paper on Case: Parks v. LaFace Records
Facts that Led to the Law Suit

There was a dispute about a name of a song. Rosa Parks was a civil right activist whose prominence arose in 1955 when she led the Montgomery Alabama Bus Boycott. LaFace Records and Outcast, a record producer and rap music group respectively, produced a song and titled it Rosa Parks including lyrics that depicted some of the activist’s past actions.

Issues

Rosa Parks sued LaFace and OutKast for false advertising and intrusion of her right to publicity under t § 43(a) of the Lanham Act, 15 U.S.C. § 1125.  She sued the defendants in the Way County Circuit Court in Michigan claiming that the Defendants illegally used her name in their songs thus infringing her right to publicity, defaming her character, and interfering with her business relationships. On their part, the Defendants maintained that the Plaintiff, Rosa Parks, failed to prove that the song violated her right to publicity. Additionally, the Defendants claimed the First Amendment, which gave artists the freedom of expression, could defend the plaintiff’s claims.

 

Actions of the Trial Court

The District Trail Court granted summary judgment for the Defendants, LaFace, and OutKast, on Rosa Parks’ claims of defaming her name and interfering with her business relations.

Elements of Lanham Act Section 43 (a) Cause of Action

The Lahman Act Action 43(a) creates a civil action against an individual who identifies his or her product in a way that is likely to cause confusion to consumers by making them associate the product with another person. The trial court ruled that Lahman Act was not violated, as there was no representation that the plaintiff endorsed the song. Secondly, the name of Outkast appears prominently in the song, thereby curing any form consumer confusion. Lastly, any presence of consumer confusion was overwhelmed by the defendant’s claims about the First Amendment.

Argument for OutKast about Artistic Relevance

The Defendants used Parks’ name metaphorically or symbolically. There existed a historical association between the plaintiff’s name and the phrase “move to the back of the bus” thus disputing Parks’ claim that the song is not about her. In addition to that, Rosa Parks was a well-known figure for refusing to move to the back of the bus, thereby making the song inarguably about her.

Rogers Test Argument for Rosa Parks

In applying the Rogers Tests, the defendants cannot be protected by the First Amendment since they infringed the right of purchasers by misleading them about the source of the song. Besides, the defendant’s song was given a title that has artistic relevance to the action of the Rosa Parks in the Montgomery-Alabama Bus Boycott.

Comparison with Other Cases

Unlike the Mattel Case, the Rosa Parks v. LaFace brings claims of defamation and effects on business relations. However, the two cases are similar because the First Amendment protects the defendants regarding the lyrics in the songs. In Seale v. Gramercy case, the defendants made a movie that they depicted the Plaintiff in the cast. Unlike in Rosa Parks vs. La Face, the defendant directly mentioned the plaintiff in the works. However, like Seale v. Gramercy, the court still ruled for the defendants

Ruling of the Court

The court reversed the District Court’s ruling on Lanham and Rosa Parks’ Ground of publicity claim but reaffirmed the decision on Rosa Parks claims of defamations and interference of the business relationships.

 

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