Jay-Z Asks Court to Revive Extortion Case After Accuser Recants Rape Claim

Jay-Z is asking a California appeals court to revive his extortion and defamation lawsuit against Houston attorney Tony Buzbee after the woman who accused the rapper of rape formally recanted her allegations under oath.

The rapper, whose legal name is Shawn Carter, cited the woman’s new declaration as “explosive new evidence” in a petition asking the California Court of Appeal to reconsider its September 9 decision upholding the dismissal of his case. Carter wants his claims returned to Los Angeles County Superior Court, where he sued Buzbee and his law firm in 2024.

The woman, identified in court records as Jane Doe, said under penalty of perjury that Carter never raped her and that she has never met or spoken to him. Her declaration was filed last week in Manhattan federal court as part of Carter’s separate malicious prosecution case.

Carter argues the reversal changes the evidentiary picture considered by the California courts and supports his request for limited discovery into Buzbee’s handling of the allegations.

His challenge faces more than the question of whether Doe’s original accusation was true. The appeals court previously found that Buzbee’s demand letters were protected communications made in anticipation of litigation and were covered by California’s litigation privilege. It also concluded that Carter had failed to show actual malice necessary to support his defamation claim.

The court reached those conclusions on the record available at the time. Carter is now arguing Doe’s sworn declaration warrants another look at that record and could lead to evidence supporting his claims.

The declaration also addresses circumstances surrounding the dismissal of Doe’s sexual assault lawsuit against Carter and Sean “Diddy” Combs in February 2025. She said she had expressed doubts about her allegations before agreeing to dismiss the case and that one of her lawyers traveled to Alabama to obtain her signature on the dismissal papers.

Doe also said she never received a threat from Carter or anyone acting on his behalf and that no lawyer discussed or obtained her authorization for a settlement.

Those statements conflict with evidence considered during the earlier California proceedings. Buzbee previously submitted declarations from Doe in which she said her allegations were true and that she dismissed the case because she feared retaliation. She also said her lawyers had extensively interviewed her and that she authorized Buzbee to send a demand letter and pursue the lawsuit.

The appeals court relied on that record when it upheld the dismissal of Carter’s California claims. Associate Justice Anne Richardson wrote that the evidence did not show Buzbee accused Carter of raping Doe while knowing the allegation was false or while recklessly disregarding whether it was true. Declarations submitted by Buzbee and other lawyers stated that their investigations led them to believe the allegations.

The court also upheld the trial judge’s refusal to allow Carter to conduct limited discovery. His lawyers had sought to depose Doe and Buzbee, but the appellate panel found several grounds supported the denial, including the timing and scope of the request and attorney-client privilegeattorney-client privilegeAttorney-client privilege protects confidential communications between a lawyer and a client when they are made for the purpose of seeking or providing legal advice. The privilege generally allows the client to prevent those communications from being disclosed in court or during litigation.Read more → concerns.

Carter now argues the sworn recantation changes the basis for that decision.

“Carter asks only that he have the opportunity to prove his case through limited discovery on remand,” his petition states. His lawyers argue that if discovery produces the evidence they expect, a jury should decide the dispute.

The legal battle began after Buzbee sent Carter a November 2024 demand letter concerning Doe’s allegations. Her federal lawsuit initially accused Combs and an unnamed celebrity of sexually assaulting her after the 2000 MTV Video Music Awards when she was 13. The complaint was later amended to identify Carter as the second alleged assailant.

Carter denied the accusation and sued Buzbee, alleging civil extortion, defamation, and intentional infliction of emotional distress. Los Angeles County Superior Court granted Buzbee’s motion to strike the claims in June 2025 under California’s anti-SLAPP law, which allows courts to dispose of certain lawsuits arising from protected speech or petitioning activity at an early stage.

The Second District Court of Appeal unanimously affirmed that ruling earlier this month.

Buzbee and his attorneys are challenging Carter’s use of Doe’s new declaration. Buzbee said last week that several lawyers had dealt with Doe before he did and that she had given them the same account. He said an admission that she lied to her lawyers and the court would amount to new information.

In a subsequent filing, Buzbee attorney Jessica Meyers called the declaration “bought-and-paid-for,” while offering no evidence that Doe was compensated. Doe said in her declaration that she received no payment or other compensation in exchange for recanting her allegations.

Meyers also argued that the new account conflicts with Doe’s earlier sworn statements and maintained there was no evidence Buzbee or his legal team knew she was lying when they relied on her allegations.

Carter’s separate malicious prosecution case remains pending in federal court in New York, although he dismissed Doe as a defendant last week. He continues to pursue claims against Buzbee and others involved in bringing the original sexual assault case.

The California Court of Appeal must now decide whether Doe’s sworn reversal provides grounds to reconsider its September 9 ruling or leave the dismissal of Carter’s claims intact.