The suit was filed in 2014 by New York musician Joel McDonald, who performs under the stage name Joel Mac. He claimed "Made in America" – the penultimate cut on Watch the Throne and one of two songs on the album to feature a hook from Ocean – stole its concept from his 2009 song of the same name. A district court dismissed the case in September 2015, ruling McDonald did not have a strong enough case. Last Friday, an appeals court upheld the lower court's decision.
"We have considered all of McDonald’s arguments and find them to be without merit," the higher court ruled.
The case also named frequent West producers Mike Dean and Shama Joseph as defendants, along with Universal Music Group, Roc-A-Fella Records, Def Jam Music and Roc Nation. McDonald represented himself.
The "Made in America" decision follows a previous Watch the Throne copyright case filed by soul singer Syl Johnson after the album's release in 2011. Johnson claimed West and Jay used an unauthorized sample of his song "Different Strokes" on "The Joy" – a track on the deluxe version of the album – and ultimately settled with the duo in 2012 for an undisclosed amount.