Over four years ago, Chance The Rapper (aka Chancelor Bennett) was sued by his former manager, Pat ‘The Manager’ Corcoran. Corcoran claimed that he was owed millions in unpaid commissions after being terminated in April 2020.
We suggested at the time that the music business would be talking about the case for years to come as a cautionary tale about when an independent artist and their manager refuse to sign a deal with a record label… or a written contract between each other.
Corcoran claimed there was a verbal agreement that Chance would pay him commission during their working relationship and for three years after termination.
Chance, via his legal team, argues that the alleged verbal agreement violates the so-called ‘Statute of Frauds’ (which requires certain contracts lasting longer than one year to be in writing) and should be dismissed.
Now, it looks like the long-running legal battle is headed to trial after a judge in Illinois denied Chance’s motion for summary judgment last week.
There are two cases currently pending in Illinois involving the dispute between Chance and his former manager, Patrick Corcoran.
As we reported at the time, the first arrived in late 2020, a few months after Corcoran was terminated as Chance’s manager (in April of that year).
Corcoran (via Pat The Manager LLC) sued three companies owned by Chance (Chance the Rapper, LLC, Cool Pop Merch, LLC, and CTR Touring, Inc.), alleging that Chance’s companies had breached a verbal contract for Corcoran’s management services to the artist.
Pat The Manager LLC sought damages for alleged unpaid commissions earned prior to being terminated as Chance’s manager, and commissions claimed to be owed on profits generated by Chance’s companies for three years after termination (i.e., through April 27, 2023).
Chance then filed his own explosive suit in February 2021, accusing his “disgruntled former manager” of having “repeatedly breached his fiduciary responsibilities to Mr. Bennett by trading on Mr. Bennett’s good name for his own benefit”. (Corcoran filed a counterclaim against Chance for breach of contract.)
The rapper also filed a motion to dismiss Corcoran’s lawsuit in addition to filing his own. In July 2021, the court dismissed most of Corcoran’s initial claims – but the one that remained was the allegation that Corcoran was owed commissions for the three years after the pair’s business relationship ended.
Last Wednesday (March 26), the court rejected motions for partial summary judgment filed on behalf of Chance and his entities in both cases.
Chance and his entities filed a motion against Pat The Manager’s breach of contract claim, and a motion against Corcoran’s breach of contract counterclaim.
“Mr. Bennett looks forward to further demonstrating at trial that this claim by his disgruntled former manager is entirely meritless.”
Chance the Rapper’s legal team
“We respectfully believe that the Court incorrectly denied summary judgment, as there is no legal or factual basis for Mr. Corcoran or his entity to obtain additional compensation from Mr. Bennett or his entities for a full three years after Mr. Corcoran was fired,” reads a statement sent to us by Chance the Rapper’s legal counsel following last week’s order.
They added: “Mr. Bennett looks forward to further demonstrating at trial that this claim by his disgruntled former manager is entirely meritless.”
With the court’s denial of summary judgment on March 26, the case will continue toward trial. The judge’s order specifically noted, however, that Chance has not been precluded from disputing the existence or terms of the alleged verbal agreement at trial, as he only conceded the plaintiff’s factual allegations for purposes of the summary judgment motion.
Chance’s Statute of Frauds argument
Last week, the Judge rejected arguments that the Statute of Frauds doctrine should prevent Corcoran’s claims for unpaid commissions, citing the “full performance” exception to the legal requirement that certain contracts be in writing.
The Illinois Statute of Frauds requires that contracts lasting longer than one year be in writing to be enforceable. Since the alleged agreement included a three-year post-termination commission period and was never put in writing, Chance argued the claim should be dismissed.
That argument was countered by invoking the “full performance” exception to the Statute of Frauds, which the court recognizes when one party has fulfilled their obligations under a contract.
The rationale, as explained in the judge’s order, obtained by MBW, and which you can read here, is that “when one party, in reasonable reliance on the contract, performs all of its obligations, it would be unfair to allow the other party to accept the benefits under the contract but to avoid its reciprocal obligations by asserting the Statute of Frauds.”
The judge’s order specifically distinguished this case from typical employment contracts, noting that “PTM is not an employee of CTR. Rather, PTM performed specific services with the contemplation (if he is to be believed) that he was receiving partial compensation now with further compensation for that same work for a continuing period of three years.”
Patrick Corcoran’s lawsuit, filed in November 2020
The legal battle began in November 2020 when Pat Corcoran, through his company Pat The Manager LLC, sued Chance the Rapper for over $3 million in allegedly unpaid commissions. The lawsuit followed Corcoran’s termination as Chance’s manager on April 27, 2020, after working together since 2012.
Corcoran claimed they established a verbal agreement in June 2013 for a 15% commission on net profits from Chance’s music, merchandise, and touring revenue.
His lawsuit sought three primary forms of compensation: reimbursement of $2.5 million allegedly invested in Chance’s career, $3 million in unpaid historical commissions, and 15% of net profits for three years post-termination.
The dispute intensified following the commercial performance of Chance’s debut studio album The Big Day, released in July 2019. After poor ticket sales, a planned 30-city global tour was canceled. According to Corcoran’s lawsuit, Chance replaced him with the artist’s brother (Taylor Bennett) and father (Ken Bennett) following these setbacks.
Chance The Rapper countersues in February 2021
In February 2021, Chance filed a countersuit against Corcoran, presenting a dramatically different account of their relationship.
Chance described Corcoran as “a hanger-on at the fringes of the rap music scene” who “had no prior success in managing artists” before meeting Chance in 2012.
The rapper acknowledged hiring Corcoran on an “at-will basis” with a verbal agreement for 15% of net profits, but disputed any post-termination obligations.
Chance’s countersuit sought at least $1 million in damages for breach of fiduciary duty, tortious interference with prospective economic advantage, and breach of contract.
The legal battle represents a significant twist in what was once celebrated as a success story of artist independence.
As noted in Corcoran’s lawsuit, which you can read here, under his management, Chance the Rapper achieved considerable success without signing to a traditional record label, winning three Grammy awards in 2017.
Corcoran’s lawsuit describes their partnership as having “reimagined and forever changed musical artists’ ability to control their careers,” noting that through his “revolutionary management style” and Chance’s “indisputable musical talent,” they “upended traditional norms, broke barriers and redefined the music industry.”
Chance, however, emphasized his own achievements in his countersuit, noting that The Big Day “debuted at No.2 on the Billboard 200″ and that he was “the first artist to achieve that feat without a recording, distribution, or publishing deal.”Music Business Worldwide
