Mariah Carey Victorious in Copyright Lawsuit Over "All I Want For Christmas Is You"
Mariah Carey has emerged victorious in a copyright infringement lawsuit alleging that her iconic holiday hit, "All I Want For Christmas Is You," illegally copied elements from a song of the same name released years prior by two other songwriters. A federal judge in Los Angeles sided with Carey, dismissing the lawsuit and averting a trial.
The legal battle was initiated by Louisiana songwriter Andy Stone, professionally known as Vince Vance, and Tennessee native Troy Powers. The duo claimed they co-authored and released their own version of "All I Want For Christmas Is You" in 1988 and 1989, respectively, several years before Carey’s Christmas anthem debuted in 1994 and subsequently became a perennial holiday staple.
Stone and Powers filed a $20 million lawsuit on November 1, 2023, targeting Carey, her co-writer Walter Afanasieff, and record label Sony Music Entertainment. The lawsuit asserted that Carey’s song unlawfully appropriated melodies, lyrics, and other musical components from their earlier work. The plaintiffs specifically pointed to the song’s "extended comparison between a loved one and trappings of seasonal luxury" as evidence of the alleged infringement.
However, U.S. District Judge Monica Almadani ruled against Stone and Powers, granting Carey’s request for summary judgment. The judge determined that the plaintiffs’ music experts failed to demonstrate sufficient "objective similarity" between the two songs using what is known as an "extrinsic test," a legal standard used to evaluate copyright infringement claims.
Judge Almadani concurred with the defense’s argument that Carey’s 1994 hit utilizes common tropes and musical elements frequently associated with Christmas songs that predate the 1989 release of the plaintiffs’ song. This finding was critical in the judge’s decision, effectively undermining the plaintiffs’ claim of copyright infringement.
Representatives for Carey, Afanasieff, and Sony Music Entertainment have been contacted for comment on the ruling.
Gerald Fox, the attorney representing Stone and Powers, expressed his disappointment with the court’s decision. He noted that copyright cases of this nature often face similar outcomes, suggesting an inherent difficulty in proving infringement. Fox indicated that his client is considering an appeal to the Circuit Court level within the next week.
Fox further criticized the court’s dismissal of testimonies provided by his musicology experts, Dr. Matthew Sakakeeny and Robert W. Fink. He argued that the dismissal left the defense’s arguments unchallenged. "Our client retained two of the most accomplished experts teaching music at two of the United States top universities and did not file until in a blind process both opined that there was infringement," Fox stated. "Sadly, it appears that the district courts routinely dismiss most plaintiff’s copyright cases."
Notably, Fox has previously represented clients in copyright infringement cases, including one against Taylor Swift over her song "Shake It Off." That case concluded with an undisclosed settlement.
This lawsuit marks the second time Vance has pursued legal action related to "All I Want For Christmas Is You." He initially filed a lawsuit in 2022, later dropping it. The initial suit focused on claims of "unique linguistic structure" allegedly copied by Carey and Afanasieff.
The latest lawsuit also alleged that Vance and Powers’ version of the song charted several times throughout the 1990s, implying that Carey and Afanasieff had access to it and potentially drew inspiration from it. The plaintiffs also argued that the title "All I Want For Christmas Is You" was "distinctive" in 1988, further supporting their claim of copyright infringement.
The lawsuit stated that the combination of the specific chord progression in the melody paired with the verbatim hook was a greater than 50% clone of Vance’s original work, in both lyric choice and chord expressions. Vance alleged his song charted on the Billboard Hot Country Chart in January of 1994, nine months before Carey’s song debuted. "(This) points to the overwhelming likelihood that Carey and Afanasieff both career musicians and songwriters, who knew the importance of charting on Billboard, had access to the Vance work prior to the composition of the infringing work in question," according to the lawsuit.
Despite these arguments, Judge Almadani ultimately sided with Carey, concluding that the plaintiffs failed to provide sufficient evidence to establish copyright infringement. The ruling reinforces the challenges faced by plaintiffs in music copyright cases, particularly when dealing with common musical themes and lyrical tropes. While Stone and Powers consider their options for appeal, Mariah Carey can continue to enjoy the ongoing success and widespread popularity of her holiday classic without the shadow of this legal dispute. The song’s enduring appeal remains undeniable, cementing its place as a timeless Christmas favorite.
