The Talent Agencies Act: Does One Year Really Mean One Year

The issue of whether the one year statute of limitations period mandated by California's Talent Agencies Act really means one year has recently been considered by the California Court of Appeal. In Park v. The Deftones, the court held that the one year limitations period is revived when a manager sues an artist. The same court, in Styne v. Stevens, held that while a lawsuit by a manager revived the statute of limitations, it revived it only for an additional one year period. This paper explores the case of Styne, the scope of the Talent Agencies Act, the jurisdiction of the court to decide issues of first impression under the Act, as well as the scope and ramifications of the Styne case.

Interestingly, as of the publication of this article, the California Supreme Court has granted review in the Styne case in an attempt to clarify the law.