ESTATE OF GEORGE BERNARD WORRELL, JR., v. THANG, INC.; GEORGE CLINTON - Articles

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Posted by: Azya Thornton on May 27, 2026

Court: 6th Circuit Court (Published Opinions)

Attorneys 1: ARGUED: Richard S. Busch, KING & BALLOW, Nashville, Tennessee, for Appellant. Erik W. Scharf, THE SCHARF APPELLATE GROUP, Miami, Florida, for Appellees.

Attorneys 2: ON BRIEF: Daniel D. Quick, DICKINSON WRIGHT PLLC, Troy, Michigan, Jonathan B. Koch, DICKINSON WRIGHT PLLC, Grand Rapids, Michigan, for Appellant.

Attorneys 3: ON BRIEF: Erik W. Scharf, THE SCHARF APPELLATE GROUP, Miami, Florida, James P. Allen, Sr., Peter E. Doyle, SCHENK & BRUETSCH PLC, Detroit, Michigan, for Appellees.

Judge(s): BOGGS, BATCHELDER, and MOORE, Circuit Judges

Court Appealed: United States District Court for the Eastern District of Michigan at Flint

KAREN NELSON MOORE, Circuit Judge. The year was 1997, and George Bernard (“Bernie”) Worrell, Jr., stood on stage at the Rock & Roll Hall of Fame. Rock & Roll Hall of Fame, Parliament-Funkadelic’s Rock & Roll Hall of Fame Acceptance Speech | 1997 Induction, YouTube (June 15, 2020), https://youtu.be/EmOmNz5Ak-g. He was there for his induction as part of the pioneering funk group Parliament-Funkadelic (“P-Funk”). Although Worrell left P- Funk in the early 1980s, he played a central role in its rise, working as a composer, arranger, “keyboardist of astonishing ability,” and “one of a writing team of three . . . behind ‘hit after hit in the heyday of P-Funk.’” R. 133-3 (Exner Report ¶ 24) (Page ID #3568) (citation modified). Smiling to the side during Worrell’s remarks was the band’s charismatic leader, George Clinton, decked out in a gilt robe and frizzy white wig, sunglasses resting on his forehead. Beneath the surface of this celebration, which honored one of the 1970s’ most groundbreaking and enduringly influential musical acts, lay a long-running and unresolved dispute. Clinton’s and Worrell’s musical synergies never translated into a smooth or simple legal relationship. Quite the opposite. Their decade of collaboration is littered with informal and contested agreements, including a purported 1976 contract (“1976 Agreement”) granting Thang, Inc. (Clinton’s company) full ownership of sound recordings that Worrell worked on, in exchange for royalties. On top of that, Clinton and Thang were allegedly not in the habit of paying Worrell, under the 1976 Agreement or otherwise. As Worrell’s wife Judie put it: Clinton “was busy hauling in the funky dollar bills and NOT sharing with those who made the MUSIC possible.” R. 134-12 (Judie Worrell Blog at 5) (Page ID #4199). Worrell died in 2016. In 2019, his estate (the “Estate,” which is the plaintiff here) sued Thang in New York state court for breach of contract, a claim that Thang successfully defended on the ground that Worrell lacked a countersigned copy of the 1976 Agreement. In 2022, the Estate changed tack and sued in federal court, seeking a declaration of its joint ownership of recordings Worrell created with P-Funk and, in turn, an accounting of royalties due. Clinton and Thang moved for summary judgment, arguing that the statute of limitations on the Estate’s copyright claims had long since run. The district court agreed and entered judgment in the defendants’ favor. This is not a contract case, as the Estate’s contract claims under the 1976 Agreement were decided in the New York court. Notwithstanding the 1976 Agreement’s invalidity, which is now res judicata, the Agreement remains the focus of the Estate’s statute-of-limitations argument. Worrell, the Estate argues, justifiably understood that the Agreement, not federal copyright law, governed his recordings with P-Funk. Accordingly, the Estate insists, Worrell’s ownership rights under copyright law were not plainly and expressly repudiated until 2020 when Clinton and Thang denied the Agreement’s validity, at which point the copyright-ownership claims accrued. We agree with the Estate that genuine disputes of material fact preclude judgment as a matter of law. Viewing the case’s highly unusual facts in the light most favorable to the Estate, part of Worrell’s copyright-ownership claim is timely. We therefore REVERSE the district court’s judgment and REMAND for further proceedings.

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