Beverly Glen Music, Inc. v. Warner Communications, Inc.
California Court of Appeal
224 Cal. Rptr. 260 (1986)
Singer Anita Baker signed a record deal with Beverly Glen Music (plaintiff) paying her under $6,000 a year. After her first album, Warner Communications (defendant) offered her a better deal, and she left Beverly Glen for Warner. Beverly Glen first sued Baker directly to enjoin her from performing for Warner, but California law barred that injunction because her contract paid less than the state's $6,000 statutory threshold, even though her talent was unique. Beverly Glen then sued Warner itself, seeking to enjoin Warner from employing Baker; the trial court denied that injunction too, and Beverly Glen appealed.
Whether a court will enjoin an employer from hiring someone bound by a personal-services contract with another employer unless the services are unique and the contract meets the state's minimum annual-earnings threshold.