Hold Wichita State University Accountable for Exploiting Music Alumni


Hold Wichita State University Accountable for Exploiting Music Alumni
The Issue
THE BACKSTORY: NIKOYLE NOEL
These two young Kansas musicians don’t knock Bach, but they want to stretch classical music to include hip-hop and R&B influences. Da'Kneisha Nikoyle Blount is a soulful songstress scribing stories of both reality and escape. Justin Noel Hall is an aural architect erecting edifices of awe-inspiring soundscapes. Two kindred souls. One dynamic symphony.
There’s a conversation going on within the classical music community that concerns itself with the lack of racial and gender diversity with personnel both on and off stage. Although women have made significant strides as conductors, musicians and composers, we’re not seeing enough music written by Black composers played by orchestras and chamber groups.
THE BREACH
Dr. Timothy "Tim" Shade invited Da’Kneisha Nikoyle Blount and Justin Noel Hall to dinner. Justin’s mother, father, God-mother, and friend, Renee Macdonald, were also in attendance, along with Tim’s wife, Samantha. During the dinner, Tim remarked about the importance of spotlighting new composers and talent, particularly in the current time we were in. He made a point to recognize the racial and gender identities of the two composers as well; Da’Kneisha is a dark-skinned, Black woman and Justin is a Black man and how that plays a role in the creation and presentation of the music, and how he wanted to champion their unique perspectives specifically. (May 5, 2021)
Later, Tim initiated a conversation with Justin and Da'Kneisha about commissioning a new piece for the WSU Wind Ensemble. Tim offered to pay them $500 per written minute of music for a new composition at HIS recommendation, verbally. No written contract was drafted. (June 25, 2021)
Justin and Da'Kneisha learn that another composer and colleague, Robert Tindle, has also been commissioned to write a new piece for the WSU Wind Ensemble for the same concert.
They end up collaboratively writing a 20-minute (totally $10,000 in payment) wind ensemble piece, "Khronos," for him and the university over an 8-month period with a deadline of February 1, 2022.
The Wind Ensemble premieres the piece at the Collegiate Band Directors National Association (CBDNA) Southwestern Division Conference at Baylor University, April 1, 2022.
Normally, the Wind Ensemble would play a May concert, but Tim elects to do a recording session of Khronos instead. After the two-hour session, when asked for payment, Dr. Shade says he can only pay $2-3,000 (70% less than the agreed rate). Da'Kneisha and Justin leave without payment.
Da'Kneisha and Justin are contracted by the Wichita Art Museum to perform. They seek out students at WSU to play for the concert, and begrudgingly ask Tim to conduct only because he knows the piece. Tim uses terms like honorarium, hire and compensation when speaking about the students and demands they get paid $100 each. The students end up receiving $90 after negotiations between Tim, Da'Kneisha and Justin via email. Ultimately, they come $870 out of pocket to pay the student musicians. No written contract was drafted. (June 22, 2022)
Justin discovers Tim had been withholding a video/recording of their premiere performance of Khronos on his personal YouTube channel. Justin finds out in passing from a colleague who says "you guys should upload it onto Spotify so I can listen to it there." (February 13, 2024)
Robert Tindle, the other composer commissioned for the CBDNA concert back in April 2022, confirms he was paid $5,000 for his 10-minute piece on August 7, 2025. He characterizes Tim giving him the run-around and having to really hound him to get paid fully. Robert also notes that Tim DENIED to sign his original contract and that they would work something out in person. No written contract was drafted.
Upon receiving this new information, Justin writes to Marie Bukowski, Dean of the College of Fine Arts about this situation giving a full comprehensive timeline of the series of events and to show how there's evidence and precedence which prove they are owed payment ($10,000) for Khronos, a recording and an apology.
WSU General Counsel submits the "university admits no liability in the case" and only offers $3,000 (70% less) and a signed release as compensation.
Da'Kneisha and Justin don't accept their offer.
They STILL haven't received an official recording from the premiere in April 2022, a copy from the recording session in May 2022, or compensation from the composition from Feb 2022.
THE WORK: KHRONOS - for Solo Soprano and Wind Ensemble
THE PROOF
- Written document showing notes from a BRAINSTORMING CONVERSATION BETWEEN TIM (in person), JUSTIN (in person) AND DA’KNEISHA (via phone) detailing "$500 per minute of music written" rate suggested by Tim after Justin asks what would be an acceptable rate to charge for the piece of music to be written. Original piece length was agreed to be 10-15 minutes; estimating a commission of $5,000-7,500 upon completion. Ultimately, we were given the greenlight to write up to 20 minutes because of changes with the concert program which would then mean a payment of $10,000.
- A former grad student recounts Dr. "Shade 100% talked to me all the time about how he was PAYING you to write that piece."
- Another commissioned composer and former WSU student, Robert Tindle, begrudgingly received their full amount of payment without a signed contract (for the same job, same pay rate and concert cycle), even after the aforementioned party initiated the deal with their own contract of which Tim refused to sign.
- Consortiums were suppose to be made for both pieces, but only one was made for Robert's piece (by a grad student). Khronos' consortium was suppose to be Tim's responsibility, but never came to fruition. The former grad student explained, "I DID want to also [create] the consortium for Khronos and I asked, but Tim told me no, he said he would do it and that he was handling that project himself. To the best of my memory and understanding, it was his intent to pay Justin for Khronos just as Robert was meant to be paid. Both pieces were commissioned at basically the same time, for the same CBDNA program, and Tim and I were meant to each organize consortiums for them. I always assumed he was working his own network for that and trusted that it would get done, so I never asked him about Khronos or discussed the consortium/commission for Khronos."
- Tim to this day has us listed on his website as a commission: "The promotion and creation of new music is a passion of Shade's. He has been involved in over 20 commissions and has worked with composers such as David Maslanka, Andrew Boysen Jr., Steven Bryant, Edward Largent, James Leatherbarrow, Jonathan Newman, Christopher Rouse, Michael Daugherty, Roberto Sierra, Paul Rudy, Steve Danyew, Derek Jenkins, Justin Hall, Robert Tindle, Thomas Sleeper, Paul Dooley, and James Syler. Shade’s recent world premiere performances include La Finta Giardiniera by W.A. Mozart-transcribed by Shade, Orbits by Robert Tindle-transcribed by Shade, and Symphony No. 2 by James Syler. Current projects include a new work for wind ensemble and voice by Justin Hall (Nikoyle Noel), a new work for wind ensemble by Robert Tindle..." (via https://www.timothymshade.com/bio)
THE DAMAGES
- Without receiving the agreed upon amount of $500 per minute of written music, Da’Kneisha and Justin had no monetary gain from their eight months of work writing a new composition for Tim and the WSU Wind Ensemble. They wrote a 20-minute piece that would have cost $10,000, and they have yet to receive monetary compensation.
- Without a recording of their composition, Da’Kneisha and Justin had no proper record of their music from the premiere performance at the Collegiate Band Directors National Association (CBDNA) 2022 Southwestern Conference.
- Da’Kneisha and Justin had to discover a recording of their piece existed on Tim’s YouTube channel months after it was online, only because a colleague mentioned to Justin that he wanted to listen to their music on Spotify.
- Without receiving any money from Tim, Da’Kneisha and Justin’s momentum of their music ventures came to a halt because of a lack of funds.
- Justin suffered a “creative” depression due to his disappointment and betrayal of a trusted and esteemed former professor.
- When seeking payment from WSU in November of 2025, Da'Kneisha and Justin were offered only $3,000 with a release as recompense via WSU General Legal Counsel, 70% less than what the other composer was paid by rate. They both denied the offer as it disrespectfully lower than what was originally discussed at their first meeting in June of 2021.
- Da’Kneisha and Justin feel there’s both racial and gender discrimination occurring due to another colleague, who happens to be a white man, receiving his full compensation of $5,000 and them not receiving any compensation, especially since both agreements were made for the same concert performance.
- At the end of the day, they felt they were manipulated into working for free to make the university and Tim look good at CBDNA. Mark Spede, then-president of CBDNA, remarked to both of them how much he enjoyed their piece, "Khronos." Justin also had an existing professor-student relationship with Tim that he feels was abused and manipulated because of his reverence to Tim and the work-relationship they had built over the years; Justin was the percussion section leader for a year in grad school, and also the music office graduate staff-assistant his second year. Da'Kneisha and Justin both feel they were seemingly spot lit because of our identities, and then simultaneously unpaid in spite of those identities.
FULFILLMENT
$30,000
A proper audio recording of KHRONOS from the PREMIERE PERFORMANCE at CBDNA and/or RECORDING SESSION if available.
An APOLOGY

414
The Issue
THE BACKSTORY: NIKOYLE NOEL
These two young Kansas musicians don’t knock Bach, but they want to stretch classical music to include hip-hop and R&B influences. Da'Kneisha Nikoyle Blount is a soulful songstress scribing stories of both reality and escape. Justin Noel Hall is an aural architect erecting edifices of awe-inspiring soundscapes. Two kindred souls. One dynamic symphony.
There’s a conversation going on within the classical music community that concerns itself with the lack of racial and gender diversity with personnel both on and off stage. Although women have made significant strides as conductors, musicians and composers, we’re not seeing enough music written by Black composers played by orchestras and chamber groups.
THE BREACH
Dr. Timothy "Tim" Shade invited Da’Kneisha Nikoyle Blount and Justin Noel Hall to dinner. Justin’s mother, father, God-mother, and friend, Renee Macdonald, were also in attendance, along with Tim’s wife, Samantha. During the dinner, Tim remarked about the importance of spotlighting new composers and talent, particularly in the current time we were in. He made a point to recognize the racial and gender identities of the two composers as well; Da’Kneisha is a dark-skinned, Black woman and Justin is a Black man and how that plays a role in the creation and presentation of the music, and how he wanted to champion their unique perspectives specifically. (May 5, 2021)
Later, Tim initiated a conversation with Justin and Da'Kneisha about commissioning a new piece for the WSU Wind Ensemble. Tim offered to pay them $500 per written minute of music for a new composition at HIS recommendation, verbally. No written contract was drafted. (June 25, 2021)
Justin and Da'Kneisha learn that another composer and colleague, Robert Tindle, has also been commissioned to write a new piece for the WSU Wind Ensemble for the same concert.
They end up collaboratively writing a 20-minute (totally $10,000 in payment) wind ensemble piece, "Khronos," for him and the university over an 8-month period with a deadline of February 1, 2022.
The Wind Ensemble premieres the piece at the Collegiate Band Directors National Association (CBDNA) Southwestern Division Conference at Baylor University, April 1, 2022.
Normally, the Wind Ensemble would play a May concert, but Tim elects to do a recording session of Khronos instead. After the two-hour session, when asked for payment, Dr. Shade says he can only pay $2-3,000 (70% less than the agreed rate). Da'Kneisha and Justin leave without payment.
Da'Kneisha and Justin are contracted by the Wichita Art Museum to perform. They seek out students at WSU to play for the concert, and begrudgingly ask Tim to conduct only because he knows the piece. Tim uses terms like honorarium, hire and compensation when speaking about the students and demands they get paid $100 each. The students end up receiving $90 after negotiations between Tim, Da'Kneisha and Justin via email. Ultimately, they come $870 out of pocket to pay the student musicians. No written contract was drafted. (June 22, 2022)
Justin discovers Tim had been withholding a video/recording of their premiere performance of Khronos on his personal YouTube channel. Justin finds out in passing from a colleague who says "you guys should upload it onto Spotify so I can listen to it there." (February 13, 2024)
Robert Tindle, the other composer commissioned for the CBDNA concert back in April 2022, confirms he was paid $5,000 for his 10-minute piece on August 7, 2025. He characterizes Tim giving him the run-around and having to really hound him to get paid fully. Robert also notes that Tim DENIED to sign his original contract and that they would work something out in person. No written contract was drafted.
Upon receiving this new information, Justin writes to Marie Bukowski, Dean of the College of Fine Arts about this situation giving a full comprehensive timeline of the series of events and to show how there's evidence and precedence which prove they are owed payment ($10,000) for Khronos, a recording and an apology.
WSU General Counsel submits the "university admits no liability in the case" and only offers $3,000 (70% less) and a signed release as compensation.
Da'Kneisha and Justin don't accept their offer.
They STILL haven't received an official recording from the premiere in April 2022, a copy from the recording session in May 2022, or compensation from the composition from Feb 2022.
THE WORK: KHRONOS - for Solo Soprano and Wind Ensemble
THE PROOF
- Written document showing notes from a BRAINSTORMING CONVERSATION BETWEEN TIM (in person), JUSTIN (in person) AND DA’KNEISHA (via phone) detailing "$500 per minute of music written" rate suggested by Tim after Justin asks what would be an acceptable rate to charge for the piece of music to be written. Original piece length was agreed to be 10-15 minutes; estimating a commission of $5,000-7,500 upon completion. Ultimately, we were given the greenlight to write up to 20 minutes because of changes with the concert program which would then mean a payment of $10,000.
- A former grad student recounts Dr. "Shade 100% talked to me all the time about how he was PAYING you to write that piece."
- Another commissioned composer and former WSU student, Robert Tindle, begrudgingly received their full amount of payment without a signed contract (for the same job, same pay rate and concert cycle), even after the aforementioned party initiated the deal with their own contract of which Tim refused to sign.
- Consortiums were suppose to be made for both pieces, but only one was made for Robert's piece (by a grad student). Khronos' consortium was suppose to be Tim's responsibility, but never came to fruition. The former grad student explained, "I DID want to also [create] the consortium for Khronos and I asked, but Tim told me no, he said he would do it and that he was handling that project himself. To the best of my memory and understanding, it was his intent to pay Justin for Khronos just as Robert was meant to be paid. Both pieces were commissioned at basically the same time, for the same CBDNA program, and Tim and I were meant to each organize consortiums for them. I always assumed he was working his own network for that and trusted that it would get done, so I never asked him about Khronos or discussed the consortium/commission for Khronos."
- Tim to this day has us listed on his website as a commission: "The promotion and creation of new music is a passion of Shade's. He has been involved in over 20 commissions and has worked with composers such as David Maslanka, Andrew Boysen Jr., Steven Bryant, Edward Largent, James Leatherbarrow, Jonathan Newman, Christopher Rouse, Michael Daugherty, Roberto Sierra, Paul Rudy, Steve Danyew, Derek Jenkins, Justin Hall, Robert Tindle, Thomas Sleeper, Paul Dooley, and James Syler. Shade’s recent world premiere performances include La Finta Giardiniera by W.A. Mozart-transcribed by Shade, Orbits by Robert Tindle-transcribed by Shade, and Symphony No. 2 by James Syler. Current projects include a new work for wind ensemble and voice by Justin Hall (Nikoyle Noel), a new work for wind ensemble by Robert Tindle..." (via https://www.timothymshade.com/bio)
THE DAMAGES
- Without receiving the agreed upon amount of $500 per minute of written music, Da’Kneisha and Justin had no monetary gain from their eight months of work writing a new composition for Tim and the WSU Wind Ensemble. They wrote a 20-minute piece that would have cost $10,000, and they have yet to receive monetary compensation.
- Without a recording of their composition, Da’Kneisha and Justin had no proper record of their music from the premiere performance at the Collegiate Band Directors National Association (CBDNA) 2022 Southwestern Conference.
- Da’Kneisha and Justin had to discover a recording of their piece existed on Tim’s YouTube channel months after it was online, only because a colleague mentioned to Justin that he wanted to listen to their music on Spotify.
- Without receiving any money from Tim, Da’Kneisha and Justin’s momentum of their music ventures came to a halt because of a lack of funds.
- Justin suffered a “creative” depression due to his disappointment and betrayal of a trusted and esteemed former professor.
- When seeking payment from WSU in November of 2025, Da'Kneisha and Justin were offered only $3,000 with a release as recompense via WSU General Legal Counsel, 70% less than what the other composer was paid by rate. They both denied the offer as it disrespectfully lower than what was originally discussed at their first meeting in June of 2021.
- Da’Kneisha and Justin feel there’s both racial and gender discrimination occurring due to another colleague, who happens to be a white man, receiving his full compensation of $5,000 and them not receiving any compensation, especially since both agreements were made for the same concert performance.
- At the end of the day, they felt they were manipulated into working for free to make the university and Tim look good at CBDNA. Mark Spede, then-president of CBDNA, remarked to both of them how much he enjoyed their piece, "Khronos." Justin also had an existing professor-student relationship with Tim that he feels was abused and manipulated because of his reverence to Tim and the work-relationship they had built over the years; Justin was the percussion section leader for a year in grad school, and also the music office graduate staff-assistant his second year. Da'Kneisha and Justin both feel they were seemingly spot lit because of our identities, and then simultaneously unpaid in spite of those identities.
FULFILLMENT
$30,000
A proper audio recording of KHRONOS from the PREMIERE PERFORMANCE at CBDNA and/or RECORDING SESSION if available.
An APOLOGY

414
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Petition created on December 29, 2025