A California appeals court has rejected Jay-Z’s attempt to revive his extortion and defamation lawsuitagainst the Texas lawyer who filed the stunning, since-dismissed complaint accusing the music mogul of raping a 13-year-old girl.
In a 24-page ruling
obtained by Rolling Stone, the appellate court said attorney Tony Buzbee did not act with malice when he briefly represented the woman who accused Jay-Z, whose legal name is Shawn Carter, of sexually assaulting her alongside Sean Combs at an afterparty for the MTV Video Music Awards in 2000.
“The record contains no evidence Buzbee accused Carter of raping Jane Doe while knowing those statements to be false or with reckless disregard as to whether they were true. To the contrary, Buzbee submitted declarations showing his firm’s and [a referral firm’s] investigations led him to subjectively believe in the truth of the accusations,” Associate Justice Anne Richardson wrote in the unanimous ruling from California’s Second Appellate District.
The ruling also found that Buzbee was protected by the litigation privilege when he sent a demand letter to Carter before he named the “Empire State of Mind” rapper as a defendant in Jane Doe’s lawsuit. “Buzbee’s and Jane Doe’s declarations indicated litigation was genuinely contemplated in good faith. And Jane Doe sued Carter after he declined to mediate,” the ruling states.
“Sending a basic demand letter prior to filing suit is not and will never be ‘extortion,’” Buzbee said in a statement to Rolling Stone on Thursday. “The plaintiff distorted the truth and twisted facts. I expected the case to be dismissed and now that it has been, I look forward to recovering my every penny of my fees and expenses.”
Attempts to reach Carter’s high-powered lawyer, Alex Spiro, were not immediately successful.
Carter first sued Buzbee in late 2024, alleging that the prominent Houston lawyer knew he was advancing false claims when he filed a lawsuit accusing Carter of raping Jane Doe with Combs. Carter said Buzbee had sent him two demand letters in early November 2024 seeking money to resolve the allegations privately. Weeks later, after Carter declined to engage, Buzbee publicly identified him as the previously unnamed John Doe co-defendant in Jane Doe’s lawsuit, according to Carter.
Los Angeles County Judge Mark Epstein held multiple hearings on Buzbee’s motion to dismiss the lawsuit, initially signaling he would allow some of Carter’s defamation claims to proceed. Then at a subsequent hearing, he said he was inclined to let the Roc Nation founder proceed with his extortion claim as well. He said he reconsidered his position based on a private investigation of the Jane Doe submitted by Jay-Z’s lawyers.
The new evidence that briefly upended the dispute was a recorded conversation between private investigators and the Jane Doe on her front porch in Alabama in February 2025. The woman allegedly said, “It was more Diddy, but Buzbee brought Jay-Z into it.” She appeared to tell the investigators that it was Buzbee who “pushed” her into publicly naming Jay-Z as one of her assailants.
“If one accepts Doe’s statements to the investigators at face value, then she at least inferentially did not authorize the settlement letter to be sent or even conclude that she was going to sue Carter at the time the [letter was] mailed,” Judge Mark Epstein wrote in a tentative ruling issued in March 2025. “Without a present intent to bring a lawsuit, the litigation privilege will fail.”
Rolling Stone previously obtained a portion of the alleged doorstep discussion with the Jane Doe. In the snippet, one of the investigators specifically asked if Doe was saying that Carter was at the afterparty but “didn’t have anything to do with any sexual acts towards you.”
“Yeah,” Doe replied. The other investigator then asked if it was Buzbee who suggested Jay-Z had a role in the alleged attack. “He was the one that kind of pushed me towards going forward with him, with Jay-Z,” the woman replied.
Buzbee’s lawyers challenged the recording’s admissibility and relevance. Carter’s camp was allowed to submit it, and the judge reviewed it before issuing his final dismissal ruling. He said the conversation was “not as clear as either party would like” and noted that Jane Doe later claimed she had felt intimidated and threatened by the investigators.
In his 65-page ruling ultimately upheld by the appellate panel, Judge Epstein dismissed Carter’s lawsuit in full but acknowledged that he was not “wholly satisfied” with the outcome. He wrote that he had tried to balance the competing interests and would leave it to the appeals court to determine whether he was “right or wrong.” He closed the ruling with two words: “stay tuned.”
When Jay-Z first sued Buzbee, he alleged the attorney was “shamelessly“ trying to extort him while representing dozens of plaintiffs with claims against Combs. He vehemently denied the allegations, and Jane Doe went on to voluntarily dismiss her entire complaint against Carter and Combs, admitting there were inconsistencies in her story.
In a sworn statement, Carter said that he considered Buzbee’s demand letter an “existential threat.” “I felt that Mr. Buzbee was placing a gun to my head that I either bow to his demands or endure personal and financial ruin. His actions caused me mental anguish about the ticking time bomb and what it would do to me, my family, and my hard-earned reputation,” he wrote.
Despite Wednesday’s appellate ruling, Buzbee still faces a separate lawsuit from Carter. The rap star has a malicious prosecution case pending against the lawyer in federal court in New York.
Combs, meanwhile, is serving a 50-month prison term for his 2025 conviction on two counts of transportation to engage in prostitution. He also denied the allegations made by Jane Doe and those of dozens of other plaintiffs in a wave of sexual abuse lawsuits.
“No matter how many lawsuits are filed, it won’t change the fact that Mr. Combs has never sexually assaulted or sex-trafficked anyone — man or woman, adult or minor,” his lawyers previously told Rolling Stone.
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