Lil' Joe Records, Inc. v. Christopher Won, Jr.

── Lil' Joe Records, Inc. v. Christopher Won, Jr. ── Court: Court of Appeals for the Eleventh Circuit Date: June 02, 2026 Category: NEW USCA11 Case: 24-13978 Document: 52-1 Date Filed: 06/02/2026 Page: 1 of 14 FOR PUBLICATION In the United States Court of Appeals For the Eleventh Circuit ____________________ No. 24-13978 ____________________ LIL’ JOE RECORDS, INC., a Florida corporation, Plaintiff-Counter Defendant-Appellant, versus MARK ROSS, Defendant, CHRISTOPHER WONG WON, JR., RODERICK WONG WON, LETERIUS RAY, ANISSA WONG WON, LUTHER CAMPBELL, et al., Defendants-Counter Claimants-Appellees. USCA11 Case: 24-13978 Document: 52-1 Date Filed: 06/02/2026 Page: 2 of 14 2 Opinion of the Court 24-13978 ____________________ Appeal from the United States District Court for the Southern District of Florida D.C. Docket No. 1:21-cv-23727-DPG ____________________ Before JILL PRYOR, LUCK, and BRASHER, Circuit Judges. BRASHER, Circuit Judge: This appeal presents a question of first impression at the in- tersection of copyright and bankruptcy. The Copyright Act gives artists a “termination interest”—the right, after a certain amount of time, to reclaim the copyright in their work despite having granted it to a third party. An artist’s termination interests are per- sonal and inalienable, although they can be passed to an artist’s heirs. Invoking this part of the Copyright Act, Mark Ross and two other members (or their successors in interest) of the rap group 2 Live Crew purported to terminate grants of copyright in five of the group’s albums. Because the rap group had four members, these three members could decide as a majority to reclaim the copyrights for the group. Here’s where bankruptcy law comes in. About twenty years before Ross signed the notice to terminate, he filed a Chapter 7 bankruptcy. When someone files for bankruptcy, the Bankruptcy Code says that all that person’s interests in property enter the bank- ruptcy estate, “notwithstanding any provision in . . . applicable nonbankruptcy law” that “restricts or conditions transfer of such interest[s] by the debtor.” 11 U.S.C. § 541(c)(1). Ross’s termination interests were never mentioned or addressed in the bankruptcy USCA11 Case: 24-13978 Document: 52-1 Date Filed: 06/02/2026 Page: 3 of 14 24-13978 Opinion of the Court 3 proceedings. And the Bankruptcy Code says that any property in a Chapter 7 estate that isn’t addressed by the bankruptcy court re- mains property of the estate until it is. Id. § 554(c), (d). Lil’ Joe Records, Inc., which eventually acquired the copy- rights, argues that 2 Live Crew did not terminate their copyright grants. Among other things, it says that Ross’s termination inter- ests (to the extent he had any at all) were held by his bankruptcy estate at the time he attempted to exercise them. We agree. De- spite the Copyright Act’s alienability restriction, we conclude that Ross’s interests became part of his bankruptcy estate and were held as property of that estate at the time he purported to exercise them. Because a majority of 2 Live Crew did not exercise their termina- tion interests, Luke Records s