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Manager's Law License Considered in California Personal Jurisdiction Ruling in Dispute Involving Rapper Lil Wayne

What is the impact of a law license on whether a court has personal jurisdiction over an attorney involved in litigation with an artist the attorney formerly managed? This was addressed in a management-fees lawsuit attorney Ron Sweeney filed against Florida-based rap artist Lil Wayne (Dwayne Carter Jr.) and Wayne's Young Money businesses, in the U.S. District Court for the Central District of California. Sweeney v. Carter, 2:21-cv-01689. Sweeney and his Avant Garde Management claim Lil Wayne initially hired the plaintiffs for personal management as the result of a 2005 meeting between Sweeney and Lil Wayne in Los Angeles; the rapper claims he engaged Sweeney to be his entertainment attorney. Sweeney bases his complaint — which alleges contract breach, fraudulent inducement and unjust enrichment, among other things — on four purported oral agreements he and Lil Wayne entered into between 2008 and 2018. (Lil Wayne fired Sweeney in 2018). Central District Judge Otis D. Wright II explained that Sweeney is seeking alleged unpaid management commissions that include: "outstanding 10% commissions owed for management work prior to May 2018, in violation of the 2008 Commissions Agreement; the balance of Sweeney's 10% share of the Cash Money [Records, to which Lil Wayne had signed] and UMG/SoundExchange [unpaid-royalties lawsuits] settlements, in violation of the 2013 Litigation Agreement [between Lil Wayne/Sweeney] made in Atlanta, Georgia; all of Sweeney's promised 10% share of the 2020 UMG master recordings [$100 million-plus sale by Lil Wayne], in violation of the 2013 Masters Agreement made in Atlanta, Georgia; and outstanding 17% commissions owed for May-September 2018 management work, in violation of the 2018 Increased Commissions Agreement." But Lil Wayne moved to dismiss Sweeney's lawsuit on the ground that the California federal court lacked either general or specific personal jurisdiction over the rapper. Agreeing with Lil Wayne, District Judge Wright found — regarding Sweeney's California law license in part as to specific jurisdiction, "First, Plaintiffs assert that Sweeney 'made [Carter] well aware of the fact' that Sweeney is a California attorney. However, it is undisputed that Sweeney maintained a New York office and used that address in his correspondence with Carter and Defendants while working for them. And although Sweeney's email signature notes Sweeney is licensed in California, it does not specify he is licensed only in California. Carter also attests that Sweeney claimed to live in and practice law in New York while working for Carter. Given that Plaintiffs touted their significant New York connections to Defendants, the record does not support that Defendants contemplated consequences in California. Further, … Plaintiffs specifically disavow the notion that Defendants hired Plaintiffs merely for legal services, so the forum of Sweeney's license does not support a finding that Defendants purposefully availed themselves of California representation."