SDNY Judge Dismisses Part of Woody Allen's Lawsuit Over Amazon Movie Deal Cancellation
A U.S. District Court judge dismissed four "duplicative" claims from the suit, which seeks more than $68 million that Allen said he was owed to produce a series of films for Amazon.
July 31, 2019 at 04:50 PM
4 minute read
The original version of this story was published on New York Law Journal
A New York federal judge has dismissed part of a lawsuit from Woody Allen and his production company over Amazon Studios' decision to walk away from a movie deal amid renewed scrutiny of the director.
U.S. District Judge Denise Cote of the Southern District of New York on Wednesday dismissed four “duplicative” claims from the suit, which seeks more than $68 million that Allen said he was owed to produce a series of films for Amazon.
According to court documents, Amazon entered an agreement in 2017 with Allen's company, Gravier Productions Inc., to acquire the rights to four planned films, with the option to pick up two more. However, Amazon backed out of the deal last summer, citing comments Allen had made about the #MeToo movement and an old allegation that the director had sexually abused his stepdaughter. That allegation has been denied by Allen.
Allen filed suit in February, claiming the cancellation was an “unjustifiable” breach of a series of contracts he and Amazon had executed. Amazon, however, said Allen's past made it impossible to market the films in the #MeToo era, and that top talent had refused to refused to work with him.
Cote's ruling tossed claims for breach of contract, implied covenant and unjust enrichment against Amazon, but did not address the contractual issues related to four specific movies, including the film “Rainy Day in New York,” which had been scheduled for release in 2019.
As to the long-term relationship, Cote said Allen had not alleged any damages for contractual breaches that were separate from claims he had proffered under the four single-picture agreements. Claims for breaches of the implied covenant of good faith and fair dealing were dismissed on a similar basis.
“None of these promises are, in fact, distinct from the contractual obligations laid out in the parties' contracts,” Cote said in the 17-page ruling.
“These claims are entirely redundant of the plaintiffs' claims for breach of contract and therefore must be dismissed,” she said.
Cote also dismissed as duplicative Allen's claim that Amazon had improperly benefited from the publicity of working with him. However, that claim too was covered by claims under the multipicture acquisition agreement, which were dismissed.
“Where, as here, however, the parties agree that a contract governs their dispute, a plaintiff may not continue to litigate a duplicative unjust enrichment claim,” she said. “The allegations in the complaint make out a straightforward breach of contract case—Allen and Gravier assert that they have performed their obligations under the parties' agreements and Amazon Content failed to hold up its end of the bargain.”
Attorneys for both sides were not immediately available to comment on Wednesday.
Allen is represented by Julia Marie Beskin, Jomaire Alicia Crawford and Donald J. Reinhard of Quinn Emanuel Urquhart & Sullivan in New York and John B. Quinn and Gary E. Gans from the firm's Los Angeles office.
The two Amazon entities in the suit, Amazon Studios and Amazon Content Services, are represented by Robert N. Klieger, Moez M. Kaba and Michael Todisco of Hueston Hennigan in Los Angeles.
The case is captioned Gravier Productions v. Amazon Content.
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