A Los Angeles County judge has cleared the most consequential claim in Andra Day’s lawsuit against her former manager to proceed, marking a significant early victory for the Grammy-winning singer in a case that cuts to the heart of how artists are protected, or fail to be protected, by the people they trust most.
In a four-page ruling issued Thursday (April 9), Judge Andrew Esbenshade denied former manager Jeffrey Evans’ bid to dismiss the central civil theft allegation in Day’s breach of contract lawsuit. The judge found Day had “sufficiently” pled the claim, allowing it to survive. He also rejected Evans’ attempt to block the possibility of triple damages, ruling the manager failed to demonstrate Day had waited too long to seek enhanced recovery.
“This is a significant win for Ms. Day,” Day’s attorneys James Sammataro and Benjamin Akley said in a statement to Rolling Stone. “It ensures that her civil theft claim will move forward and that the handling of her income will be subject to scrutiny in court.”
The ruling is notable partly because of what Judge Esbenshade highlighted in reaching it. Evans had already admitted in a December court filing that his companies “mistakenly withheld” $575,486 in funds owed to Day and had agreed to return the money. The judge ruled that at this early stage, Day had made a viable claim that Evans intended to permanently deprive her of those funds, which is the legal threshold for civil theft as opposed to simple breach of contract. Day’s lawsuit characterized the admission as Evans being “caught red-handed,” noting the funds were only acknowledged after her new legal team began investigating the situation in 2023.
The full picture painted by Day’s lawsuit is damaging. Her complaint alleges that Evans, through his companies BassLine Management and Buskin Entertainment, misappropriated a $600,000 recording fund from Warner Records, siphoned more than $1 million from her publishing and master recording income, charged her for “extravagant” personal travel, and failed to segregate her publishing income into a separate account as required. Day alleges their management agreement expired on June 30, 2023, but that Evans continued taking commissions afterward.
The financial consequences for Day, according to the lawsuit, were severe. “He siphoned so much money from Day, a quadruple-platinum hitmaker and Golden Globe Best Actress winner, that he left her facing eviction, unable to pay the monthly minimum on her credit card debt, and without sufficient funds to tour,” the complaint reads. By the time a new attorney began investigating in 2023, Day alleges she had more than $300,000 in credit card debt and was on the verge of being evicted.
Evans tells a starkly different story. He filed his own lawsuit one day before Day filed hers, in October 2025, claiming he is owed commissions on recordings and compositions Day created before a 2018 contract revision. His suit points to Day’s 2024 publishing deal with Kobalt, which he alleges has paid her over $1 million, and argues she owes him a 40% cut of that sum. Evans claims Day has already “recouped all monies owed” and now owes him more than $850,000 in unpaid commissions and royalties.
The two cases are now consolidated under Judge Esbenshade in downtown Los Angeles. A trial-setting conference is scheduled for June 25.
The case fits into a broader and troubling pattern in the music industry. The structure of artist-manager relationships, particularly for artists who sign long-term deals early in their careers before they have experienced legal counsel, frequently leaves artists exposed to exactly the kind of financial entanglement Day describes. As the FKA twigs case against Shia LaBeouf and the Chance the Rapper trial testimony have illustrated, disputes over financial fiduciary duties in the music industry are rarely simple. What makes the Day case particularly pointed is the judge’s willingness to let the civil theft framing, with its potential for triple damages, survive the first legal challenge. That framing is now heading toward discovery, where financial records, contracts, and communications will be subject to court scrutiny.
