## Facts

- Paisley Park Enterprises, Inc. and Comerica Bank & Trust, N.A., as personal representative of the Estate of Prince Rogers Nelson (collectively, the Prince Estate), sued George Ian Boxill (a sound engineer who worked with Prince) and related individuals and entities.
- The Prince Estate alleged defendants unlawfully possessed and attempted to commercially exploit previously unreleased Prince sound recordings.
- The complaint included multiple claims, including breach of contract, conversion, and copyright infringement.
- The Prince Estate demanded arbitration of the breach-of-contract and conversion claims pursuant to an arbitration clause in Boxill’s confidentiality agreement.
- Boxill moved in federal court to enjoin the arbitration, arguing federal copyright law preempted the contract and conversion claims; the court denied the request and arbitration proceeded.
- After an evidentiary hearing, the arbitrator issued an interim award for the Prince Estate on breach of contract and conversion, awarding damages and ordering the return of the disputed recordings.
- The arbitrator later issued a final award that also granted the Prince Estate reasonable attorneys’ fees and costs.
- Boxill moved to vacate the award under the Federal Arbitration Act (FAA), and the Prince Estate cross-moved to confirm the award and for entry of judgment (including interest and fee relief).

## Issues

1. Whether Boxill showed a valid ground under the FAA to vacate the arbitration award (including an argument that the arbitrator exceeded her authority by rejecting copyright-preemption defenses).
2. Whether the court should confirm the award and enter final judgment under Federal Rule of Civil Procedure 54(b), including awarding post-award prejudgment interest and enforcing the award’s fee-and-cost component.

## Decision

- Denied Boxill’s motion to vacate the arbitration award.
- Granted the Prince Estate’s motion to confirm the arbitration award.
- Entered final judgment on the confirmed award under Rule 54(b), finding no just reason for delay despite other remaining claims in the broader litigation.
- Awarded post-award prejudgment interest and enforced the award of reasonable attorneys’ fees and costs.

## Legal Principles

- FAA review of arbitration awards is highly limited; a court confirms an award unless a party proves a narrow statutory basis for vacatur, modification, or correction.
- A court does not re-try the case on the merits; claimed legal or factual error by the arbitrator is not enough, even if the court believes the arbitrator was wrong.
- An arbitrator generally acts within her authority when she resolves defenses and legal questions that are part of the submitted dispute, including federal preemption arguments, when the parties have agreed to arbitrate the claims.
- When no FAA vacatur ground is shown, confirmation is mandatory, and the court may enter partial final judgment under Rule 54(b) on the arbitrated claims when they are distinct enough from the remaining claims and immediate judgment is warranted.
- Post-award prejudgment interest may be awarded to compensate for the period between the arbitration award and entry of judgment, and prevailing-party fee-and-cost relief may be enforced when included in (or supported by) the arbitration award.

## Conclusion

In Paisley Park Enterprises v. Boxill, the District of Minnesota confirmed an arbitration award in favor of the Prince Estate arising from alleged misuse of unreleased Prince recordings, rejecting Boxill’s attempt to vacate the award under the FAA because his arguments amounted to merits disagreement rather than a statutory vacatur ground; the court also entered Rule 54(b) judgment and granted post-award prejudgment interest along with the award’s attorneys’ fees and costs.


Paisley Park Enterprises v. Boxill, 371 F. Supp 3d 578 (2019)