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Where consideration of the defense of illegality would involve the court in admitting potentially extensive, confusing, and prejudicial evidence, it is within the court's discretion to disallow such an inquiry.
In this action, plaintiff Elvin Associates, whose principal is Ashton Springer, alleges that defendants Aretha Franklin and Crown Productions, Inc. breached a contract under which Franklin was to star in a New York musical production entitled "Sing Mahalia Sing" ("Mahalia"), which Elvin Associates was to produce and manage. Defendants have denied that they entered into the contract upon which Elvin Associates is suing and have asserted a counterclaim alleging breach by Elvin Associates of a second contract relating to the same production.
Was the district court the appropriate place to determine if the producer had violated a state court's injunction?
The court found for Elvin Associates. The court held that the contract itself violated no third party's rights because Elvin Associates’ entry into the contract with Aretha Franklin and Crown Productions did not of itself violate the injunction. The court concluded that a federal jury trial was not an appropriate forum for determining whether or not any actions by Elvin Associates in carrying out the contract intentionally or unintentionally violated an injunction issued by a state court and, if so, what sanctions should be applied.