Salt-N-Pepa Lawsuit Against UMG: Dismissal and Second Circuit Appeal

The Salt-N-Pepa lawsuit against UMG is a copyright fight in which Cheryl “Salt” James and Sandra “Pepa” Denton are trying to reclaim ownership of their early master recordings, including the 1987 hit “Push It.” A federal judge in Manhattan dismissed the case in January 2026 after finding the duo never owned the copyrights in the first place, and the pair is now appealing to the U.S. Court of Appeals for the Second Circuit, with oral arguments expected no earlier than late 2026.¹

What Salt-N-Pepa Are Trying to Reclaim

The dispute is about four albums recorded between 1986 and 1993: Hot, Cool & Vicious, A Salt With a Deadly Pepa, Blacks’ Magic, and Very Necessary. Universal Music Group ended up controlling that catalog through corporate acquisitions of the labels that originally distributed it.²

On May 15, 1986, James and Denton signed a recording agreement with Noise In The Attic Productions, a company owned by their producer and manager Hurby “Luv Bug” Azor. That contract named NITA as the “sole and exclusive owner” of the master recordings and all copyrights. The same day, Azor signed a separate distribution agreement with Next Plateau Records that passed those rights along to the label. James and Denton were not signatories to that distribution deal; they signed only an attached “inducement letter.”³

In March 2022, the duo served UMG with Notices of Termination under Section 203 of the Copyright Act of 1976. That provision lets authors reclaim copyright transfers 35 years after the original grant, a right Congress created because artists tend to sign away rights early in their careers with little leverage.⁴ UMG rejected the notices, taking the position that the recordings were “works made for hire” and that Salt-N-Pepa had never owned the copyrights to begin with.⁵

The duo filed suit on May 19, 2025, in the U.S. District Court for the Southern District of New York. The complaint sought a declaration that the termination notices were valid, an order forcing UMG to give up the copyrights, damages the duo said would “well exceed one million dollars,” and a common-law conversion claim over the physical master tapes.⁶

The Streaming Removal

Starting in mid-2024, Salt-N-Pepa’s early catalog began disappearing from Spotify, Apple Music, and other streaming platforms.⁷ The lawsuit framed the removal as retaliation, alleging UMG was willing to hold the duo’s rights “hostage even if it means tanking the value of Plaintiffs’ music catalogue and depriving their fans of access to their work.”⁸ UMG called the takedowns a “necessary consequence” of the unresolved question of who could license the music.

At their Rock and Roll Hall of Fame induction in November 2025, the duo told the audience: “Fans can’t even stream our music. It’s been taken down from all streaming platforms because the industry still doesn’t want to play fair.” As of mid-2026, the four albums remain off streaming services.⁹

Why the Case Was Dismissed

UMG moved to dismiss in August 2025, and on January 8, 2026, U.S. District Judge Denise Cote granted the motion.¹⁰ The ruling turned on a threshold question. Section 203 lets an author terminate a copyright grant the author personally made. Judge Cote read the 1986 contracts as showing the only grant in the chain was NITA’s transfer to Next Plateau, not anything executed by James and Denton themselves.¹¹

The duo had argued the inducement letter was itself a direct grant of their rights to Next Plateau. The court disagreed, finding the letter required the artists to agree to representations already in the distribution agreement, including NITA’s claim of sole ownership. In the court’s reading, the letter acknowledged NITA’s rights rather than transferring the artists’ own.³ Judge Cote wrote that “the 1986 agreements do not indicate that Plaintiffs ever owned the copyrights to the sound recordings or that they granted a transfer of those rights to anyone else.”¹²

The conversion claim over the physical tapes was also dismissed. The court called the duo’s assertion of ownership “conclusory without any factual details” and again pointed to contract language assigning all interest in the tapes to NITA and then Next Plateau.¹³ Judge Cote did not formally decide whether the recordings were works made for hire, though the opinion noted UMG’s work-for-hire position was “consistent with the copyright registrations,” which listed NITA, London Records, or UMG as “employer for hire.”³

The Appeal Before the Second Circuit

Salt-N-Pepa filed a notice of appeal on February 4, 2026 (Case No. 26-253) and added attorney Richard S. Busch of Nashville-based King & Ballow to their team. Busch represented the Marvin Gaye estate in the “Blurred Lines” copyright case against Pharrell Williams and Robin Thicke.¹⁴

The 71-page opening brief, filed March 31, 2026, argued Judge Cote’s ruling was “riddled with error.”¹⁵ Its core arguments:

Copyrights vest automatically in the author when a work is fixed in tangible form. Because James and Denton created the recordings as performers, the brief argues the copyrights originated with them by operation of law regardless of what the contracts said.¹⁶
The inducement letter did contain a grant. The brief points to language in which the duo agreed to “grant you all of the rights and remedies therein granted to you,” which it says was a direct transfer from the artists to Next Plateau and therefore terminable.¹⁶
Judge Cote invented a “new requirement out of whole cloth” by demanding that the artists expressly assert copyright ownership in their contracts; the statute imposes no such rule.¹⁷
The district court committed “reversible legal error” by effectively treating the recordings as works made for hire without formally deciding that question or developing a factual record. The 1986 agreements, the brief notes, never use the phrase “made for hire.”¹⁶

The brief noted the catalog generated roughly $1 million in royalties in the five months before the suit was filed.¹⁷

Two amicus briefs followed in April 2026. Irving Azoff’s Music Artists Coalition and the Authors Alliance argued the dismissal creates a roadmap for labels to sidestep termination rights by routing contracts through third-party production companies, rendering Congressional protections “illusory.”¹⁸ The National Society of Entertainment and Arts Lawyers argued the district court should not have made a work-for-hire determination without a full record.¹

UMG filed its response on May 5, 2026, asking the Second Circuit to affirm the dismissal. The company argued the inducement letter “does not contain or refer to any grant of copyright rights” and pointed to what it called a “paradox” in the duo’s position: they claim to have made a copyright grant as authors while also having agreed in the 1986 contracts that NITA was the “author and copyright owner” from inception.¹⁹ UMG described the termination provision as a “carefully balanced scheme” and said the case “falls clearly outside the scope of any termination right created by Congress.”¹⁸

What the Case Could Mean for Other Artists

Section 203 termination rights for post-1978 works became available starting in 2013, and a series of legacy artists have tried to use them. In 2019, Bruce Springsteen, John Waite, and other musicians sued UMG in the same Manhattan court over ignored termination notices; the court declined to consolidate the claims as a class action, and some plaintiffs reached a confidential settlement with UMG in March 2024. Paul McCartney sued Sony/ATV Music Publishing in 2017 and settled, and in 2012 a California court affirmed Victor Willis of the Village People’s right to terminate his copyright assignments.²

Labels have often defended against these claims by arguing sound recordings are works made for hire and therefore exempt from termination. Congress briefly added sound recordings to the statutory work-for-hire list in 1999, then repealed the amendment the following year after artist pushback.²⁰

What sets the Salt-N-Pepa case apart is that Judge Cote did not rule on work-for-hire at all. She ruled the artists never held the copyrights to terminate. If the Second Circuit adopts that reasoning, labels may be able to defeat future termination claims by pointing to production-company contracts that placed copyright ownership with a third party from the start, sidestepping the work-for-hire fight entirely. As of June 2026, oral arguments had not been scheduled, with proceedings expected no earlier than late 2026.¹

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LawFold. Salt-N-Pepa Lawsuit Master Tapes
2
FindLaw. After Copyright Dispute With Record Label, Salt-N-Pepa Push It to Court
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Music Business Worldwide. Salt-N-Pepa Lawsuit Against UMG Over Ownership of Master Recordings Dismissed
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Billboard. Salt-N-Pepa Lawsuit Music Masters Back Record Label
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Stereogum. Salt-N-Pepa Sue UMG to Regain Masters
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Yahoo Entertainment. Salt-N-Pepa Lose Legal Battle
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Variety. Salt-N-Pepa Universal Music Appeals Court Lawsuit Masters
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