Editing Frankie Lymon (section)

===Posthumous troubles===
"I'm Sorry" and "Seabreeze" are the two songs that Lymon had recorded for Big Apple before his death, and were [[posthumous publication|posthumously released]] later in 1969.<ref>{{cite web |title=Frankie Lyman And His All Stars – I'm Sorry / Sea Breeze |url=https://www.discogs.com/release/6868610-Frankie-Lyman-And-His-All-Stars-Im-Sorry-Sea-Breeze |website=Discogs |publisher=Discogs |access-date=31 May 2024}}</ref>

Apart from the posthumous releases of these songs, Lymon's troubles extended to others after his death. After [[Diana Ross]] returned "Why Do Fools Fall in Love" to the Top Ten in 1981, a major controversy concerning Lymon's estate ensued. Having neglected to divorce any of them and each claiming to be Frankie Lymon's rightful widow, [[Zola Taylor]], Elizabeth Waters, and Emira Eagle approached Morris Levy, the music impresario who retained possession of Lymon's copyrights and his royalties. The complex issue resulted in lawsuits and counter-lawsuits, and in 1986 the first of several court cases concerning the ownership of Lymon's estate began.

Trying to determine who was indeed the lawful Mrs. Frankie Lymon was complicated by more issues. Waters was already married when she married Lymon; she had separated from her first husband, but their divorce was finalized in 1965, after she had married Lymon.<ref>Goldberg, Marv. "Marv Goldberg's R&B Notebook: The Teenagers".</ref> Taylor claimed to have married Lymon in Mexico in 1965, but could produce no acceptable evidence of their union.<ref name="ebony" /> Lymon's marriage to Eagle, on the other hand, was properly documented as having taken place at Beulah Grove Baptist Church in Augusta, Georgia, in 1967; however, the singer was still apparently twice-married and never divorced when he married Eagle. The first decision was made in Waters' favor; Eagle appealed, and in 1989, the Appellate Division of the New York State Supreme Court reversed the original decision and awarded Lymon's estate to Eagle.<ref>{{cite court |litigants=In re Lymon (Lymon v. Lymon) |vol=151 |reporter=A.D.2d |opinion=248 |pinpoint= |court=N.Y. App. Div. 1st Dept. |date=June 6, 1989 |url=https://scholar.google.com/scholar_case?case=16028121891087750258 |access-date=April 5, 2023}}</ref><ref>Bennett, Joy. ''The Real Story of "Why Do Fools Fall in Love"''. The 1998 Frankie Lymon biographical film concludes with a comical post-script stating that Elmira Eagle (now legally Elmira Eagle-Lymon) received only $15,000 from winning Lymon's estate, after legal and other expenses were paid off. An excerpt from this article states otherwise: "A major discrepancy in the movie left the impression that [Elmira Eagle-Lymon] only received a $15,000 settlement. After Diana Ross re-recorded Frankie's song "Why Do Fools Fall in Love," his estate was worth more than $1 million. Attorney [William] McCracken confirms that 'the settlement was well over seven figures.'"</ref>

However, the details of the case brought about another issue: whether mobster Morris Levy was deserving of the songwriting co-credit on "Why Do Fools Fall in Love". Although early single releases of "Why Do Fools Fall in Love" credit Frankie Lymon, [[Herman Santiago]], and Jimmy Merchant as co-writers, later releases and cover versions were attributed to Lymon and George Goldner. When Goldner sold his music companies to Morris Levy in 1959, Levy's name began appearing as co-writer of "Why Do Fools Fall in Love" in place of Goldner's. Lymon was never paid his songwriting royalties during his lifetime; one result of Emira Eagle's legal victory was that Lymon's estate would finally begin receiving monetary compensation from his hit song's success. In 1987, Herman Santiago and Jimmy Merchant, both by then poor, sued Morris Levy's estate for their songwriting credits. In December 1992, the [[U.S. District Court for the Southern District of New York]] ruled that Santiago and Merchant were co-authors of "Why Do Fools Fall in Love".<ref>{{cite court |litigants=Merchant v. Lymon|vol=828 |reporter=F.Supp. |opinion=1048 |pinpoint= |court=S.D.N.Y.|date=July 23, 1993 |url=https://scholar.google.com/scholar_case?case=43526739017844608 |access-date=April 5, 2023| }}</ref> However, in 1996 the ruling was reversed by the [[U.S. Court of Appeals for the Second Circuit]] on the basis of the [[statute of limitations]]: copyright cases must be brought before a court within three years of the alleged civil violation while Merchant and Santiago's lawsuit was not filed until 30 years later.<ref>{{cite court |litigants=Merchant v. Levy |vol=92 |reporter=F.3d |opinion=51 |pinpoint= |court=2d Cir.|date=August 7, 1996 |url=https://scholar.google.com/scholar_case?case=17363566383284114372 |access-date=April 5, 2023| }}</ref> Authorship of "Why Do Fools Fall in Love" currently remains in the names of Frankie Lymon and Morris Levy.