A federal appeals court has revived a copyright lawsuit brought by the estate of late Parliament-Funkadelic keyboardist Bernie Worrell against George Clinton and his company Thang, Inc.
The US Court of Appeals for the Sixth Circuit reversed a lower court’s dismissal of the case on Wednesday (May 27), ruling that genuine disputes of material fact remain over whether the statute of limitations bars the estate’s claims of co-ownership over P-Funk recordings made between 1976 and 1979.
A district court judge in Michigan had previously thrown out the lawsuit after determining that the statute of limitations had long expired.
The Sixth Circuit disagreed, finding that Clinton and Thang may not have “plainly and expressly repudiated” Worrell’s copyright co-ownership until 2020 – when Clinton denied the validity of a 1976 recording contract that both parties had acted in accordance with for decades.
The case, Estate of George Bernard Worrell, Jr. v. Thang, Inc. and George Clinton, was argued on April 22, 2026, with the opinion written by Judge Karen Nelson Moore.
“Having successfully argued in New York state court that the 1976 Agreement never governed their relationship with Worrell, Clinton and Thang must live with the consequence that federal copyright law, not contract law, now controls.”
Karen Nelson Moore, US Circuit Judge
The 23-page opinion, obtained by MBW, can be read in full here.
The ruling does not resolve the underlying question of whether Worrell was a co-owner of the recordings – only that the case should proceed to trial.
“Having successfully argued in New York state court that the 1976 Agreement never governed their relationship with Worrell, Clinton and Thang must live with the consequence that federal copyright law, not contract law, now controls,” Judge Moore wrote.
At the center of the dispute is a proposed 1976 contract between Thang (Clinton’s company) and Worrell, which purported to grant Thang full ownership of sound recordings Worrell worked on in exchange for royalties.
Worrell signed the agreement, but, as a New York state court later determined, Thang never countersigned it, rendering it invalid.
The Sixth Circuit found that despite the agreement’s invalidity, both parties acted for years as though it was in effect.
Thang submitted to an audit of its books when Worrell sought royalties owed under the agreement’s terms, told third-party record companies that Worrell had signed away his ownership rights, and settled a 1981 lawsuit in which Worrell alleged that Thang had failed to pay royalties under the contract.
Under these circumstances, the court found, Worrell may have justifiably viewed Clinton’s and Thang’s failure to pay royalties as a contract dispute, not as a repudiation of his underlying copyright ownership.
The estate’s copyright claims were therefore arguably not triggered until 2020, when Clinton swore in an affidavit that Thang had never signed the agreement, effectively denying that any contract governed Worrell’s rights.
The Sixth Circuit also rejected Clinton’s and Thang’s argument that the estate lacked sufficient evidence to support Worrell’s joint ownership of any P-Funk recordings.
The court found that Clinton’s own statements “contradict any suggestion that Worrell was just a session player or hired hand,” and that his contributions as a composer, arranger, and keyboardist were sufficiently original to support a claim of co-authorship under the Copyright Act.
The Sixth Circuit’s ruling is limited in scope.
It covers only recordings made during the potential term of the 1976 agreement, at most, a three-year window beginning on January 1, 1976.
Claims relating to recordings made before 1976 or after January 1, 1979, the court held, remain time-barred.
The appellate ruling arrives at a moment when Clinton is engaged in multiple legal battles over his catalog.
Earlier this month, Clinton sued UMG Recordings, alleging the label has withheld more than USD $1.1 million in royalties across at least 12 accounts for more than three years – a freeze Clinton says UMG justified by citing the Worrell estate litigation.
UMG was originally named as a defendant in the Worrell case but was dismissed in October 2023.
Clinton’s complaint against UMG describes the royalty freeze as “financially crippling” and argues the label faces no potential liability in the Worrell litigation.
The Sixth Circuit’s decision to revive the Worrell estate’s claims may complicate that separate dispute, as the underlying copyright ownership questions that the UMG lawsuit characterized as resolved are now heading back to trial.
In March 2025, Clinton also filed a lawsuit against music executive Armen Boladian and several of his companies, including Bridgeport Music and Westbound Records, accusing them of a “decades-long scheme to defraud” him of royalties and copyright ownership.
That case, in which Clinton is reportedly seeking $100 million in damages, is the latest in a series of legal disputes between the two stretching back more than 30 years.
Worrell, born George Bernard Worrell, Jr. on April 19, 1944, in Long Branch, New Jersey, was a classically trained musician who attended both the New England Conservatory of Music and Juilliard.
He met Clinton while hanging around Clinton’s barbershop in New Jersey, and went on to work with him and his bands between 1969 and 1981.
Clinton himself has described Worrell as “a founding member and Musical Director” of Parliament-Funkadelic, and acknowledged in deposition testimony that Worrell provided the group “with the structural foundation” while “radically charting the course of emerging keyboard technology during the golden age of analog synthesis.”
P-Funk “took [their] funk and rock and roll and put Bernie’s chops in it, and… had something nobody knew what the hell [they] were doing,” Clinton said in deposition testimony cited by the court.
Worrell was inducted into the Rock and Roll Hall of Fame in 1997 as part of Parliament-Funkadelic.
After leaving P-Funk in the early 1980s, he played with Talking Heads for much of that decade and was featured in their concert film Stop Making Sense.
He also collaborated with Keith Richards, Yoko Ono, Fela Kuti, and Les Claypool, among others.
Worrell died on June 24, 2016, at the age of 72, after a battle with lung cancer.
His wife, Judie Worrell, is the representative of his estate and the plaintiff in the case.
The case has been remanded to the US District Court for the Eastern District of Michigan for further proceedings.Music Business Worldwide
