Curb Records v. McGraw

Tim McGraw entered into a Personal Service Contract with Curb Records. The contract stipulated that McGraw would provide recording services exclusively to Curb.

In accordance with the contract, McGraw was required to produce 3 albums during the initial period. Afterwards, McGraw had 6 additional periods to deliver more of his music to Curb.

Curb rejected McGraw’s 5th album Emotional Traffic because the songs were allegedly old.

• Tim McGraw (defendant) = "McGraw" = famous country singer
• Curb Records, Inc. (Curb) (plaintiff) = "Curb" = record label = part of Sony Music as of 2023

Curb filed a lawsuit against McGraw to prevent him from providing his services to other record labels until McGraw had satisfied his 5th & 6th acceptable albums with Curb.

Curb lost in the trial court.

Is injunctive relief appropriate for contracts involving extraordinary & unique services?

Yes. A contract for extra-ordinary & unique services may warrant injunctive relief, but not if the terms are sufficiently definite or if an injunction would be equal to involuntary servitude.

Affirmed.

Judge Bennett: Injunctive relief is an equitable remedy to be granted only in limited circumstances.

Affording Curb sole discretion to judge the acceptability and novelty of McGraw's music will make specific performance like involuntary servitude in this case.