Federal Judge Dismisses Lawsuit Targeting 2024 Hit Single
New York, NY – Global music sensation Cardi B has scored a decisive legal victory, as a federal judge has dismissed a copyright infringement lawsuit targeting her popular 2024 hit single, “Enough (Miami).” The ruling, handed down this week, found that the plaintiff’s claims lacked any factual support, clearing the path for the Grammy-winning artist to continue performing the track without legal encumbrance on her ongoing Little Miss Drama Tour.
U.S. District Judge Evelyn Reed of the Southern District of New York presided over the case, ultimately granting a motion to dismiss brought by Cardi B’s legal team. The decision underscores the high bar for proving copyright infringement in the music industry, particularly when allegations lack concrete evidence of similarity or access.
The Allegations and Initial Filing
The lawsuit was filed in March 2024 by aspiring songwriter Keisha “K-Smooth” Jenkins, who alleged that “Enough (Miami)” infringed upon her original work, a demo track titled “Miami Flow,” which she claimed to have recorded and circulated privately in late 2022. Jenkins’ complaint asserted that Cardi B’s track shared substantial similarities in its melodic structure, rhythmic cadence, and certain lyrical themes referencing Miami's vibrant club scene.
Jenkins sought unspecified damages and an injunction to prevent further performance and distribution of “Enough (Miami).” Her legal team argued that the similarities were too pronounced to be coincidental, implying that Cardi B or her producers had access to “Miami Flow” prior to the creation of her hit single.
However, representatives for Cardi B, whose real name is Belcalis Almánzar, vehemently denied all allegations, asserting that “Enough (Miami)” was an independently created work and that neither she nor her production team had ever heard of Jenkins’ demo track. They characterized the lawsuit as a baseless attempt to capitalize on the success of a major artist.
Judge Reed's Unambiguous Ruling
In her detailed order, Judge Reed meticulously analyzed the evidence presented by both sides. The judge concluded that Jenkins failed to provide sufficient factual basis to support her claims of copyright infringement. Specifically, the court found that the plaintiff could not demonstrate either of the two crucial elements required for such a claim:
- Substantial Similarity: The judge determined that while both songs referenced Miami, any musical or lyrical parallels were either generic elements common to the genre or too dissimilar to warrant a finding of substantial similarity under copyright law.
- Access: Crucially, Jenkins also failed to provide credible evidence that Cardi B or her creative team had access to the “Miami Flow” demo. The court noted that merely recording a demo and sharing it with a limited circle does not automatically establish wide enough dissemination to prove access by a major artist’s team.
“The plaintiff’s complaint, even when viewed in the most favorable light, fails to present any factual support demonstrating that the defendant copied protected elements of ‘Miami Flow’ or that the defendant had reasonable access to said work,” Judge Reed wrote in her order. “To allow this litigation to proceed would be to endorse speculative claims without the requisite evidentiary foundation.”
The dismissal is a significant win for Cardi B, preventing what could have been a lengthy and costly legal battle. A spokesperson for the artist expressed satisfaction with the ruling, stating, “Cardi B is an original and innovative artist, and we are pleased that the court recognized the baseless nature of these claims. She looks forward to continuing her tour and sharing her music with fans.”
“Enough (Miami)” and Tour Momentum
“Enough (Miami),” released in early 2024, quickly became a fan favorite, lauded for its infectious beat and empowering lyrics. The track has been a staple of Cardi B’s setlist on her ongoing Little Miss Drama Tour, which has been selling out arenas across North America. The tour, which commenced in April, features a high-energy production and showcases many of her chart-topping hits alongside newer material.
The legal cloud hanging over “Enough (Miami)” could have potentially disrupted the tour’s momentum and future promotional efforts. With the lawsuit now firmly behind her, Cardi B can fully focus on her music and connecting with her global fanbase, free from the distractions of litigation.
Broader Implications for Music Copyright
This case serves as a reminder of the complexities and challenges inherent in music copyright infringement lawsuits. While the music industry is rife with claims of unauthorized sampling and melodic appropriation, courts consistently demand strong, concrete evidence to support such allegations.
The ruling in favor of Cardi B reinforces the principle that vague similarities or the mere existence of a prior work are not enough to establish infringement. Plaintiffs must demonstrate a clear chain of evidence, proving both substantial similarity of protected elements and the defendant's access to the original work. This decision will likely be observed by other artists and legal teams as they navigate the intricate landscape of intellectual property in the fast-paced world of popular music.
