A federal court has tentatively found that Plaintiff Amy Taylor’s Lanham Act claim cannot survive the Rogers test and that amendment may be futile.
UPDATE (March 30, 2026): Official court hearing minutes have been issued. Read the March 30, 2026 hearing minutes in Amy Taylor v. Jamie Nelson →
March 18, 2026 Tentative Ruling in Amy Taylor v. Jamie Nelson Signals Dismissal of Lanham Act Claim Under the Rogers Test
On March 18, 2026, the United States District Court for the Central District of California issued a tentative ruling in Amy Louise Taylor v. Jamie Nelson Studios LLC, et al., addressing claims brought by Plaintiff Amy Taylor against Defendant Jamie Nelson.
The Court’s tentative ruling indicates that Plaintiff Amy Taylor’s Lanham Act claim is unlikely to proceed and that her remaining state law claims would not be retained in federal court.
Lanham Act Claim: Court Finds Plaintiff Amy Taylor’s Claim Cannot Survive the Rogers Test
In its analysis, the Court applied the Rogers test, which governs Lanham Act claims involving expressive works.
After reviewing the allegations brought by Plaintiff Amy Taylor, the Court concluded:
“the Court would find that Plaintiff cannot survive the Rogers test.”
The Court explained that Defendant Jamie Nelson’s use of Plaintiff Amy Taylor’s name, image, and likeness was artistically relevant to the underlying work:
“Nelson’s use of Plaintiff’s name, image, and likeness is unquestionably ‘artistically relevant’ to the underlying work.”
The Court further found no plausible allegation of explicit deception:
“The Court… would find no ‘explicit indication,’ ‘overt claim,’ or ‘explicit misstatement’ that would cause such consumer confusion.”
As a result, the Court indicated that it would:
“GRANT the MJP on Plaintiff’s claim under the Lanham Act.”
Amendment: Court Expresses Doubt That Plaintiff Amy Taylor Can Cure Deficiencies
The Court also addressed whether Plaintiff Amy Taylor should be permitted to amend her complaint.
In doing so, the Court stated:
“the Court fails to see how Plaintiff could amend her Complaint to overcome the Rogers test”
While the Court noted it may hear further argument, it indicated that amendment may be futile.
State Law Claims: Court Declines Jurisdiction Over Plaintiff Amy Taylor’s Remaining Claims
Because Plaintiff Amy Taylor’s Lanham Act claim is the only federal claim, the Court addressed her remaining state law causes of action.
The Court explained that where federal claims are dismissed:
“the district courts may decline to exercise supplemental jurisdiction”
Accordingly, the Court indicated that it would:
“DISMISS [Plaintiff Amy Taylor’s state law claims] without prejudice.”
This means those claims would not proceed in federal court.
Procedural Posture
This ruling is tentative and was issued in advance of the March 19, 2026 hearing.
Tentative rulings reflect the Court’s preliminary analysis and may be subject to further argument before a final ruling is issued.
Summary of Tentative Ruling
According to the Court’s March 18, 2026 tentative ruling:
- Plaintiff Amy Taylor’s Lanham Act claim cannot survive the Rogers test
- The Court indicated that it would grant judgment on the pleadings as to that claim
- The Court expressed that Plaintiff Amy Taylor may not be able to amend to cure the deficiencies
- The Court indicated that it would decline jurisdiction over Plaintiff Amy Taylor’s state law claims and dismiss them without prejudice
*Below is the Court’s full 14-page tentative ruling, issued March 18, 2026, addressing dispositive motions filed by Defendant Jamie Nelson against Plaintiff Amy Taylor.
This tentative ruling was later addressed at the March 30, 2026 hearing, where the Court set a mediation schedule. Later that same day, the Court denied Plaintiff Amy Taylor’s motion for default judgment in its official minutes.
View the official March 30, 2026 hearing minutes in Amy Taylor v. Jamie Nelson →
