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Case file s1627 · Music and sport · 1968
1968
Frankie Lymon: Frankie Lymon
Frankie Lymon. Gee Records. Public domain, Wikimedia Commons.
Died
27 February 1968
Place
New York City · United States
Field
doo-wop, rock and roll · Music on the timeline
Legal tradition
US common law (New York); federal copyright law · Common law
Historical event
Morris Levy and Roulette Records; Merchant v. Levy (2d Cir. 1996)

Three women claimed to be Frankie Lymon's widow, and New York courts had to decide who owned his share of "Why Do Fools Fall in Love"

Frankie Lymon sang lead on "Why Do Fools Fall in Love" as a teenager. In 1964 Morris Levy bought George Goldner's interest in the company that held its copyright. In a letter of 24 June 1965 to the Copyright Office, Goldner named Levy, not himself, as Lymon's co-author, and the registration was changed. Lymon died of a heroin overdose in 1968, aged 25, and was buried in an unmarked grave at St. Raymond's Cemetery. In 1984 Emira Eagle, who married him in June 1967 in Georgia, sued Levy in federal court over the song. Two other women then petitioned the Surrogate's Court as his widow. Elizabeth Waters said she married him in early 1964 in Virginia; her divorce from her first husband was not final until 1965. Zola Taylor of the Platters said she married him in Mexico around 1965 but had no record. Levy's company, Big Seven Music, paid Waters a $10,000 advance and Taylor $7,500 against future royalties. In late 1988 Surrogate Marie Lambert ruled Waters the legal widow and dismissed Taylor. Eagle won on appeal in 1989, and the Court of Appeals refused to hear Waters. Teenagers Jimmy Merchant and Herman Santiago won a 1992 jury verdict as co-authors; the Second Circuit threw it out in 1996 as filed too late. Emira Eagle Lymon Bryant died in April 2019.

What the law took from it

A marriage never ended by divorce can let one spouse displace another years later, so heirs need the record of every marriage and every divorce.

Cite as: celebrity.estate, “Three women claimed to be Frankie Lymon's widow, and New York courts had to decide who owned his share of "Why Do Fools Fall in Love",” story s1627, https://www.celebrity.estate/frankie-lymon-1968, updated 30 October 2026.

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