Jay-Z’s Bid to Revive Tony Buzbee Lawsuit Faces Skeptical California Appeals Court

Jay-Z’s effort to revive his extortion and defamation lawsuit against attorney Tony Buzbee faced skepticism from a California appeals court Thursday, with a three-judge panel tentatively siding with the lower court decision that dismissed the case.

The dispute stems from a since-withdrawn lawsuit filed by an anonymous woman who accused Jay-Z, whose legal name is Shawn Carter, and Sean “Diddy” Combs of sexually assaulting her when she was 13. Carter denied the allegations. The woman later dismissed the case with prejudice, and no court ruled on the merits of her claims.

Carter then pursued claims against Buzbee and his law firm in California, alleging the attorney used false accusations and the threat of publicity to pressure him for a settlement. Los Angeles County Superior Court Judge Mark H. Epstein dismissed the case in June 2025 after granting Buzbee’s motion under California’s anti-SLAPP law.

The law allows courts to dismiss certain claims at an early stage when they arise from protected speech or activity connected to litigation. Once the law applies, the person bringing the lawsuit must show enough evidence for the claims to move forward.

A recorded interview with the woman who accused Carter became a central issue in that analysis. In the recording, she appeared to say Carter had not assaulted her and claimed Buzbee had pushed her to include him in the case. Epstein excluded the recording from the evidence he could consider, weakening Carter’s attempt to keep the lawsuit alive.

During Thursday’s oral argument, Justice Stephen Goorvitch questioned how the recording was obtained and who hired the private investigators who interviewed the woman. Carter’s attorneys have denied arranging the interview, leaving its origins unclear.

Justice Anne Richardson also questioned the reliability of the interview, pointing to the way the questions were asked and the woman’s largely brief responses. Buzbee’s attorney, Samuel Moniz, argued that the encounter was coercive and said the investigators threatened to reveal the woman’s identity if she did not cooperate.

Carter’s appellate attorney, Jeremy Rosen, urged the panel not to let the tentative ruling stand. He argued that questions surrounding the recording and the woman’s credibility should be explored through discovery rather than resolved before Carter has access to documents and witness testimony.

Rosen also argued that the lower court acknowledged the excluded recording could have changed the outcome of Buzbee’s anti-SLAPP motion. Carter is asking the appeals court to send the case back for further proceedings.

The lower court dismissal was not based solely on the recording. Epstein also found that Buzbee’s pre-lawsuit demand letters and other statements were protected by California’s litigation privilege and did not support Carter’s extortion and defamation claims.

The appellate panel took the case under submission after Thursday’s arguments. Its tentative position is not a final ruling, and the court will issue a written decision.

Carter is separately pursuing claims against Buzbee, the woman and others in federal court. That case, which includes allegations of malicious prosecution and abuse of process, was transferred from Alabama to the Southern District of New York earlier this year, where motions to dismiss remain pending.