SOCA artiste Patrice Roberts has been ordered to pay her former management company more than US$30,000 following a High Court ruling, but successfully counterclaimed for US$9,000 in unpaid digital royalties.
In a judgment delivered on Tuesday, Justice Robin Mohammed found that Soca Bookings Incorporated was entitled to compensation for services rendered to the artiste between 2015 and 2017, despite shortcomings in its contractual claim.
The dispute arose out of an oral management agreement reached in February 2015, under which the Canadian-based company provided what it described as full artiste management services, including bookings, branding, recording arrangements and international promotion.
While both sides agreed that a contract existed, the court found that key terms were never clearly settled, particularly whether management fees were immediately payable or only after the venture became profitable.
Justice Mohammed accepted Roberts’ position that fees were to be deferred until profitability was achieved, something the company failed to prove.
“The management fees were only payable once the venture became profitable and the Claimant has not established…that that threshold was ever reached,” the judge said.
Given this, the company’s contractual claim for management fees failed. However, the judge ruled that Roberts had benefited from the company’s services and must still compensate it under the principle of quantum meruit.
“She retained all financial benefits… and in those circumstances cannot in equity be permitted to benefit from the Claimant’s work without compensating it,” the judge stated.
The court awarded Soca Bookings US$22,535 for management services and a further US$8,200 for loans and advances proven to have been made on Roberts’ behalf, bringing the total award to US$30,735.
A separate claim for US$11,600 linked to a music video shoot was dismissed after the court found insufficient evidence that the expenditure had been incurred.
Roberts, however, succeeded in her counterclaim after the court found that Soca Bookings had received digital sales proceeds on her behalf but failed to properly account for them. Evidence at trial showed that the company had in fact collected such earnings, contradicting its earlier position.
With no precise financial records produced, the court accepted US$9,000 as the best available estimate of those proceeds and awarded that sum to Roberts.
Both parties were also awarded pre-judgment interest and legal costs. The judge indicated that the sums may be set off, which would result in Roberts paying a reduced balance of US$25,104.12 along with TT$26,983.71 in costs.
Soca Bookings was represented by attorneys Tara Thompson, Gideon McMaster and Joel Roper, while Roberts was represented by Sterling John and Shelly Clarke.
In concluding, Justice Mohammed warned about the risks of informal agreements in the entertainment industry, noting that the dispute could likely have been avoided if the parties had formalised their arrangement in writing.
