Chance The Rapper has failed to get what remains of a lawsuit filed by his former manager Pat Corcoran dismissed. A judge rejected the rapper’s argument that Illinois law stopped Corcoran from pursuing post-term commissions - stemming from what is known as a ‘sunset clause’ - because the pair’s previous management deal was an oral agreement.
A legal rep for the rapper told Law360 that they “respectfully” disagree with the judge, insisting “there is no legal or factual basis” for Corcoran or his company to “obtain additional compensation” from the rapper, real name Chancellor Bennett, “for a full three years after Mr Corcoran was fired”.
The lawyer then added that his client “looks forward to further demonstrating at trial that this claim by his disgruntled former manager is entirely meritless”.
The dispute between Bennett and Corcoran has been rumbling on for years now. Corcoran first sued in late 2020, claiming that - after years of success together - Bennett had started to ignore his advice, resulting in a lacklustre album and cancelled tour, which the rapper then blamed on his manager.
Which resulted in Bennett sacking Corcoran. The manager then sued for breach of contract and allegedly unpaid commissions.
Bennett countersued, insisting that Corcoran had been paid all he was due, while making allegations of misconduct against the manager. While still managing Bennett, it was alleged, Corcoran had secretly used the rapper’s fame and success to try to leverage benefits for his other businesses.
In July 2021, the court stripped back Corcoran’s lawsuit so that only the dispute over unpaid commissions remained. However, legally speaking, that was the most interesting part of the litigation anyway.
Corcoran said that his management deal with Bennett included a sunset clause, meaning he could continue to commission on any of the rapper’s income streams that he had been involved in initiating for three years after that deal formally ended. Such clauses are pretty standard in management deals.
However, there was no written agreement between Bennett and Corcoran, which is surprisingly common with management deals, but is always problematic when an artist and manager fall out. Because, needless to say, Bennett denies there was any sunset clause as part of their oral agreement.
For a time Bennett and Corcoran tried to settle their dispute out of court, but those efforts failed, and so the formal legal action proceeded. Although Bennett denies there was any agreement to pay post-term commissions to Corcoran, he initially tried to get that claim dismissed by employing some legal technicalities.
Illinois law recognises that oral contracts are legally binding, except in certain scenarios set out in what is known as the Statute Of Frauds. That law says that contracts that cannot be performed within one year must be in writing.
Bennett argued that that applied in this case. However, Corcoran said that legal precedent meant that, providing he had fully performed his obligations under the oral contract, the Statute Of Frauds did not apply. Bennett countered that that wasn’t the case in employment scenarios. But Corcoran successfully argued that his management relationship with Bennett was not an employment relationship.
Judge Patrick J Sherlock writes in his judgement, “The rule of law is that full performance on the part of one of the parties”, in this case Corcoran, “to an oral agreement bars application of the Frauds Act by the other”, ie Bennett.
Therefore the Statute Of Frauds legal technicality is not sufficient to get this case dismissed. Which means, for now, the Chance The Rapper v Pat The Manager legal battle continues.