Duties, Modification, Good Faith
Published online by Cambridge University Press: 05 June 2012
In a civilized society people must be able to assume that those with whom they deal will act in good faith.
– Roscoe PoundIMPLIED TERMS: BUTCH LEWIS AND MAYA ANGELOU
Maya Angelou is a renowned poet and professor at Wake Forest University. Since the 1969 publication of her autobiography, “I Know Why the Caged Bird Sings,” her acclaimed poetry had been published widely by Random House and initially reached a distinguished, albeit small, audience. In 1994, Butch Lewis, the former prize fighter and promoter of famous boxers such as Muhammad Ali and Joe Frazier, conceived the idea of popularizing Angelou’s poetry by including it in greeting cards and similar media. The idea proved spectacularly successful. Hallmark greeting cards using Angelou’s poetry have generated hundreds of millions of dollars in company sales and many millions in author royalties. Lewis and Angelou fought a pitched, eight-year long battle over whether they had a contract to split the take.
Lewis first met Angelou in early 1994 when the scrappy fighter asked the elegant poet to take a trip to Indiana with him to visit his boxing client, Mike Tyson, in prison. During the trip, Angelou and Lewis discussed how she might expand her readership by publishing her works in greeting cards. After negotiations, the two signed an informal letter of agreement on November 22, 1994. Angelou promised to contribute poetry exclusively to Lewis and he promised to promote its publication in greeting cards. The exclusivity feature was important because it meant Angelou could not market her poetry without Lewis and Lewis did not need to fear that his efforts would be undercut by a last-minute switch to a competing promoter.
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