In a significant decision for the music industry and copyright law, a U.S. federal court has tossed out a lawsuit that alleged Universal Music Group (UMG) had used an uncleared sample in Mary J. Blige’s 1992 hit song “Real Love.” The ruling, issued September 23, 2025, found that the sample was not substantially similar enough to the original work cited, effectively ending the case.
Background of the Dispute
Tuff City Records, a label known for safeguarding its extensive catalog of R&B, funk, jazz, soul, and hip-hop works, filed the lawsuit in 2024. The label claimed that UMG used a drum loop from “Impeach the President,” a 1973 track by The Honey Drippers, without properly securing rights or permission. The song “Real Love,” from Mary J. Blige’s debut album What’s the 411?, was alleged to have sampled this drum part.
Tuff City had previously been involved in similar copyright suits against high-profile artists, including the Beastie Boys, Jay-Z, Frank Ocean, and Kanye West (now known as Ye). Some of those cases were dismissed, some settled, and some withdrawn.
Court’s Findings
U.S. District Judge Dale Ho presided over the case in the Southern District of New York. In his ruling, Judge Ho determined that the two songs—in terms of rhythm, texture, and sound—do not share enough resemblance to support a claim of copyright infringement. The standard applied was whether a “lay listener” would perceive the newer recording as having appropriated the earlier one. Judge Ho found that this standard was not met.
Specifically, the judge stated:
“The songs do not sound the same; a lay listener would not recognize Real Love as having been appropriated from Impeach the President.”
This phrasing reflects prevailing legal doctrine that protects against claims based solely on isolated or generic elements, especially in music where certain rhythms or styles are common and widely used.
Implications for the Music Industry
This ruling has broader importance beyond just this one case:
- Precedent on Sampling Cases: The decision reinforces that sampling disputes impose a high bar. The similarity must be evident to non-experts, not just technical analyses or claims of resemblance. This may discourage attempts to litigate over ordinary rhythmic elements or commonly used drum breaks unless there is a clear and recognizable similarity.
- Rights and Clearances: While many sampling agreements are negotiated after the fact or handled proactively, this ruling underscores the need for especially strong evidence when challenging someone else’s use of a sample. Labels wanting to sue must be able to demonstrate similarity in a way that would strike listeners without musical training.
- Labels’ Risk Assessment: For artists, record labels, and rights holders, the case may affect how they assess legal risk around sampling — both in pursuing alleged infringers and in defending their own works if challenged.
What Tuff City Alleged
- Ownership: Tuff City owns the copyright to Impeach the President, and claimed that the drum pattern in Real Love was taken without authorization.
- Scope: The catalog covers many genres, with many earlier works that might otherwise be forgotten but are still under copyright protection.
Outcome and Next Steps
Because the case was dismissed, Universal Music Publishing Inc. is no longer exposed to liability in this matter. Mary J. Blige was not a defendant in the lawsuit.
For Tuff City, the dismissal means they will need to assess whether an appeal is feasible (based on permissible issues of law) or whether other claims could be brought under different legal theories or in different jurisdictions. So far, public filings indicate they will consider their options.
Conclusion
The UMG victory marks a win for standard-setting in copyright law regarding music sampling. The court’s decision confirms that not all claims based on sampling are viable; similarity must be substantial and audible to ordinary listeners, not just detectable by experts. As the music world continues to evolve with evolving technology and sampling practices, cases like this help define where the boundaries lie between inspiration, influence, and infringement.
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