Jay-Z Loses Appeal Against Tony Buzbee Over Withdrawn Rape Lawsuit
Jay-Z has lost an appeal seeking to revive his extortion and defamation claims against attorney Tony Buzbee over a since-withdrawn lawsuit that accused the rapper of raping a 13-year-old girl with Sean “Diddy” Combs.
A three-judge panel of California’s Second District Court of Appeal upheld the dismissal of claims brought by Jay-Z, whose legal name is Shawn Carter, finding that Buzbee’s pre-lawsuit demand letters were protected communications and that Carter had not produced enough evidence to keep his defamation claims alive.
The Sept. 9 ruling leaves in place a June 2025 decision by Los Angeles County Superior Court Judge Mark H. Epstein, who struck the claims under California’s anti-SLAPP law. The statute allows courts to quickly dismiss lawsuits targeting protected speech or litigation-related activity when the plaintiff cannot show a sufficient basis for the case to continue.
The dispute began after Buzbee filed a civil lawsuit against Combs on behalf of a woman identified as Jane Doe. An amended complaint filed in December 2024 added Jay-Z and accused both men of sexually assaulting her after the MTV Video Music Awards in 2000, when she was 13.
Jay-Z denied the allegation and accused Buzbee of using the threat of public accusations to pressure him into paying a settlement. The sexual assault lawsuit was voluntarily dismissed with prejudice in February 2025, but Jay-Z continued pursuing Buzbee over the way the allegations had been raised before and after the filing.
A recorded interview between Jay-Z’s private investigators and Jane Doe became a central part of that effort. His attorneys argued that the recording showed the woman saying he had not assaulted her and that Buzbee had pushed her to include him in the case.
Epstein refused to consider the recording after finding it was inadmissible hearsay, and the appeals court upheld that ruling. The judges also pointed to the circumstances surrounding the interview, including statements by investigators about Jane Doe’s anonymity and the possibility of legal action, finding those factors could have influenced what she told them and weakened the recording as evidence that Buzbee knew the allegations were false.
Without the recording, Jay-Z lacked enough evidence to show actual malice, the heightened standard public figures must meet in a defamation case. Buzbee had submitted declarations stating that investigations conducted before the lawsuit led him to believe Jane Doe’s allegations, and the appeals court found Carter had not produced admissible evidence showing Buzbee either knew the accusations were false or seriously doubted their truth.
Jay-Z also failed to revive his extortion claim. His attorneys argued that Buzbee’s demand letters went beyond ordinary settlement negotiations and amounted to threats designed to force a payment by using the prospect of public sexual assault allegations.
The appeals court sided with Buzbee, finding that the letters were tied to contemplated litigation and were sent in an effort to resolve claims before a lawsuit was filed. California law protects many communications made in preparation for litigation, including settlement demands, and the judges found Jay-Z had not shown that Buzbee’s conduct crossed into criminal extortion.
The court also upheld Epstein’s decision to limit additional discovery sought by Jay-Z, including efforts to obtain further testimony from Buzbee and Jane Doe before the anti-SLAPP motion was decided. Buzbee said after the ruling that he intends to seek recovery of the fees and costs he incurred defending the California case.
The decision does not end the legal fight between the two men. Jay-Z is still pursuing a separate case in New York federal court tied to the withdrawn sexual assault lawsuit, including a malicious prosecution claim against Buzbee and others.
That case focuses on the filing and pursuit of the underlying accusation rather than the same pre-litigation communications at issue in California, leaving Jay-Z with another path to continue the dispute despite the appellate loss.
