What was filed

The complaint is Document 1 in No. 1:26-cv-12656, U.S. District Court for the Northern District of Illinois, Eastern Division, filed October 15, 2026, and assigned to Judge LaShonda A. Hunt. The complaint itself is two pages; the filing runs 69 pages with exhibits. It is signed by Michael Brown, pro se, individually and as administrator for Lawn Music Company.

The plaintiffs are Michael Brown and Lawn Music Company, both listed at an address in Monee, Illinois. The defendants are the Estate of Willie C. Cobbs, which the complaint says is being administered in Monroe County, Arkansas (Case No. 48PR-22-4); Phillip Cobbs, individually and as executor; and Latasha Cobbs Carthans, who the complaint calls a royalty distributee with a business address at La Tasha Publishing. (Compl. p. 1.)

What the complaint alleges

It alleges that on January 28, 1971, Lawn Music and songwriter Willie C. Cobbs signed a songwriter agreement granting Lawn Music 100% of the publishing, exploitation, and renewal rights in "Slow Down, Baby" and "Hoppin' Bird"; that an October 9, 2009 assignment by Minnette Brown unified administration under Lawn Music, and that July 27, 2010 BMI agreements recognized the Estate of Joseph Charles Brown and Michael Brown as administrators and publishers of record; and that Cobbs and his successors breached the agreement by attempting to divert publishing and royalty streams, specifically by transferring publishing rights to La Tasha Publishing. It alleges that Phillip Cobbs, as executor, obtained an Arkansas probate Order for Partial Distribution attempting to distribute royalties and rights to Carthans, and that an American Arbitration Association proceeding (No. 01-22-0003-7209) was dismissed without prejudice on July 17, 2023, which the complaint attributes to a lack of formal probate estate service rather than any ruling on the merits. (Compl. pp. 1 to 2.)

Counts and relief

Count I alleges breach of the 1971 agreement and claims unrecovered royalties and arbitration expenses totaling over $15,000. Count II seeks an accounting of money collected from BMI, Harry Fox, Embassy Music, and other clearinghouses, and a constructive trust over diverted royalties. The prayer asks for damages, an accounting of royalties for the two songs and related compositions from 1994 to the present, a constructive trust over funds distributed in the Arkansas probate case, and costs, arbitration expenses, and fees. The complaint is captioned as one for breach of contract and "copyright royalties accounting" and invokes jurisdiction under 28 U.S.C. 1332 and 1338, but it pleads no Copyright Act count. The court docket lists the nature of suit as 820 Copyright. (Compl. pp. 1 to 2; Dkt. 1.)