Appeals Court Rejects Jay-Z’s Bid to Revive Extortion Lawsuit Against Attorney

A California appellate court has dismissed Jay-Z’s efforts to reinstate his extortion and defamation lawsuit against the Texas attorney who filed the now-dropped accusation that the music mogul raped a minor.

In a 24-page opinion obtained by Rolling Stone, the appellate court determined that attorney Tony Buzbee acted without malice when he briefly represented the woman who accused Jay-Z, born Shawn Carter, of sexually assaulting her alongside Sean Combs at an MTV Video Music Awards afterparty in 2000.

“The record contains no evidence indicating that Buzbee accused Carter of raping Jane Doe while knowing those statements to be false or with reckless disregard for their truth,” Associate Justice Anne Richardson wrote in the unanimous decision. “To the contrary, Buzbee’s declarations demonstrated that his firm’s and [a referral firm’s] investigations led him to subjectively believe in the validity of the accusations.”

The court also concluded that Buzbee was shielded by the litigation privilege when he sent a demand letter to Carter prior to naming the “Empire State of Mind” rapper as a defendant in Jane Doe’s lawsuit. “Buzbee’s and Jane Doe’s declarations indicated that litigation was genuinely contemplated in good faith. Jane Doe ultimately sued Carter after he declined to mediate,” the ruling states.

“Sending a basic demand letter before filing a lawsuit is not and will never be ‘extortion,’” Buzbee stated in a comment to Rolling Stone on Thursday. “The plaintiff distorted the truth and manipulated facts. I anticipated the case would be dismissed, and now that it has been, I look forward to recovering my full attorney’s fees and expenses.”

Attempts to reach Carter’s attorney, Alex Spiro, were not immediately successful.

Carter initially filed suit against Buzbee in late 2024, alleging that the prominent Houston attorney knew the claims were false when he sued Carter for the alleged rape alongside Combs. Carter claimed Buzbee sent him two demand letters in early November 2024 seeking a private resolution. After Carter refused, Buzbee publicly identified him as the previously unnamed 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, initially indicating he would allow some of Carter’s defamation claims to proceed. He later stated he was inclined to permit the Roc Nation founder to continue his extortion claim as well, noting he reconsidered his position based on a private investigation of Jane Doe submitted by Jay-Z’s legal team.

The evidence that temporarily shifted the dispute was a recorded conversation between private investigators and Jane Doe at her Alabama home in February 2025. The woman reportedly stated, “It was more Diddy, but Buzbee brought Jay-Z into it.” She appeared to suggest that Buzbee “pushed” her into publicly naming Jay-Z as one of her attackers.

“If one accepts Doe’s statements to the investigators at face value, she at least inferentially did not authorize the settlement letter to be sent nor conclude she intended to sue Carter at the time the [letter was] mailed,” Judge Epstein wrote in a tentative ruling issued in March 2025. “Without a present intent to bring a lawsuit, the litigation privilege fails.”

Rolling Stone previously obtained a portion of the alleged doorstep discussion. In the excerpt, one investigator specifically asked if Doe was saying Carter was at the afterparty but “did not have anything to do with any sexual acts towards you.”

“Yeah,” Doe replied. The other investigator then asked if Buzbee suggested Jay-Z played 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 responded.

Buzbee’s legal team challenged the recording’s admissibility and relevance. Carter’s camp was permitted to submit it, and the judge reviewed it before issuing his final dismissal. He noted the conversation was “not as clear as either party would like” and highlighted that Jane Doe later claimed she 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 he was not “wholly satisfied” with the outcome. He wrote that he had attempted 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 initially sued Buzbee, he alleged the attorney was “shamelessly” attempting to extort him while representing numerous plaintiffs with claims against Combs. Buzbee vehemently denied the allegations, and Jane Doe voluntarily dismissed her entire complaint against Carter and Combs, admitting to inconsistencies in her narrative.

In a sworn statement, Carter stated he viewed Buzbee’s demand letter as an “existential threat.” “I felt that Mr. Buzbee was placing a gun to my head, forcing me to either comply with his demands or suffer personal and financial ruin. His actions caused me immense mental anguish regarding the impending threat and its potential impact on me, my family, and my hard-earned reputation,” he wrote.

Despite Wednesday’s appellate ruling, Buzbee still faces a separate lawsuit from Carter. The rapper has a malicious prosecution case pending against the attorney in federal court in New York.

Meanwhile, Combs is serving a 50-month prison sentence following his 2025 conviction on two counts of transportation to engage in prostitution. He has also denied the allegations made by Jane Doe and numerous other plaintiffs in a wave of sexual abuse lawsuits.

“No matter how many lawsuits are filed, it will not 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.

Source link