U.S. Court Blocks Bad Bunny's Bid for Legal Fees in Afrobeats Copyright Dispute with Nigerian Music Company

A United States federal court has dealt a significant blow to Bad Bunny's legal strategy by refusing to award him and his co-defendants attorneys' fees and costs in a copyright dispute with Empawa Africa Music Services Limited, a Nigerian-founded music company. The decision, handed down by the U.S. District Court for the Central District of California on 20 August 2026, found that the defendants had failed to meet the legal threshold required to recover their legal expenses, even after securing dismissal of the case.

The dispute centred on allegations that Bad Bunny's 2022 track "Enséñame a Bailar," from his album Un Verano Sin Ti, unlawfully sampled material from "Empty My Pocket," an Afrobeats song originally created in 2019 by Ezeani Chidera Godfrey and later recorded with Nigerian artist Joeboy. Empawa Africa, the music company founded by Nigerian entrepreneur Mr Eazi, claimed exclusive ownership of the copyright and alleged that Bad Bunny's label, Rimas Entertainment, had used the sample without proper authorisation.

The Core of the Dispute

The lawsuit turned on a fundamental question: whether Lakizo Entertainment, a company operated by Adesina Lekan, had the legal authority to grant Bad Bunny permission to use the sample. Bad Bunny's team maintained they had received explicit authorisation from Lakizo, whilst Empawa disputed that Lakizo held such rights under their agreement.

According to the court record, Empawa had entered into a written agreement with Lakizo that specifically recognised Empawa's copyright ownership and did not grant Lakizo the right to license or sublicense the song. Judge Otis D. Wright II noted that the defendants had failed to produce documentation demonstrating that Lakizo actually possessed the authority to authorise the sample's use, nor did they provide evidence that such authorisation had been exercised.

The judge found Empawa's position objectively reasonable, particularly given the clear language in the licensing agreement. Significantly, the court concluded that the copyright claims brought by Empawa were "not frivolous" and that the Nigerian music company was entitled to rely on copyright registration certificates it held identifying it as the owner of the works in question.

Why It Matters for Ghana

This ruling carries important implications for African music producers and rights holders across West Africa and beyond. The case demonstrates that courts in major jurisdictions will take seriously copyright claims brought by African music companies, even when defendants are international superstars like Bad Bunny. For Ghanaian musicians, producers and music entrepreneurs, the decision reinforces that proper documentation of copyright ownership and careful attention to licensing agreements are essential protections in an increasingly competitive global music marketplace.

The decision also highlights the risks of relying on intermediaries or unauthorised sublicensors when securing samples or interpolations. As Ghana's music industry continues to grow—particularly in the Afrobeats and hiplife genres—local artists and labels must ensure that their copyright registrations are properly documented and that any licensing arrangements explicitly define what rights third parties can exercise. The case shows that major international artists cannot simply assume they have clearance to use African musical material without proper verification.

Furthermore, the ruling suggests that courts will scrutinise claims of authorisation without supporting documentation, creating a legal environment where African rights holders can mount credible challenges to unauthorised use, even against well-resourced international defendants.

Why the Case Was Dismissed

The copyright case never reached a final determination on the merits of the infringement allegations. As discovery proceeded, the case unravelled due to procedural and practical difficulties. Godfrey and Joeboy did not fully cooperate with the discovery process, and Empawa sought to resolve the matter informally. The situation was further complicated when Empawa and Godfrey's legal representatives, the firm Manatt, Phelps & Phillips, concluded they could no longer represent both parties due to an irreconcilable conflict of interest.

After the court granted the law firm's withdrawal request, Empawa was unable to retain new counsel within the required timeframe. Godfrey subsequently continued the case without legal representation but failed to prosecute it further. The court ultimately dismissed the action with prejudice for lack of prosecution, entering judgment in favour of the defendants—but notably without awarding them the attorneys' fees they sought.