Marriage of Strong CA2/1

Filed 10/29/25 Marriage of Strong CA2/1 NOT TO BE PUBLISHED IN THE OFFICIAL REPORTS

California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication or ordered published, except as specified by rule 8.1115(b). This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.

IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA

SECOND APPELLATE DISTRICT

DIVISION ONE

In re the Marriage of MONIQUE and B345843 BRETT LIVINGSTONE STRONG. ___________________________________ (Los Angeles County Super. Ct. No. BD643024) MONIQUE STRONG,

Respondent,

v.

BRETT LIVINGSTONE STRONG,

Appellant.

Appeal from order of the Superior Court of Los Angeles County, Jeffrey W. Korn, Commissioner. Affirmed. LGI and Bradley A. Patterson for Appellant Brett Livingstone Strong. Klass Helman and Ross and Robert M. Ross for Respondent Monique Strong.

Brett Livingstone Strong (Brett)1 is a sculptor who holds a copyright on certain of deceased Michael Jackson’s works, titled “The Collected Works of Jackson-Strong Alliance.” In October 2024, Brett’s estranged wife, Monique Strong (Monique), requested that the trial court order Brett to assign the copyright to a receiver so it could be monetized. She argued Brett owed her $2 million in unpaid spousal and child support and that he had no other assets that could satisfy the debt. The court granted Monique’s request. Brett now asks us to reverse that order. He does not dispute that he owes Monique $2 million or that the copyright constitutes his sole asset. He contends, instead, that no legal authority permits a court to order the forced assignment of a copyright. We disagree. Code of Civil Procedure section 695.010, subdivision (a)2 provides that, absent an exception, “all property of the judgment debtor is subject to enforcement of a money judgment.” (§ 695.010, subd. (a).) Brett, however, has not convinced us that any exception for copyrights applies. In addition, although no published California decision has yet held that a court may order the forced assignment of a copyright in particular, cases dating back to the 19th century uphold the forced assignment of other forms of a debtor’s intellectual property to satisfy a creditor’s judgment. Accordingly, we affirm.