A unanimous ruling found no evidence the Texas lawyer acted with malice when he briefly represented a woman who accused Jay-Z of sexual assault.
A California appeals court has rejected Jay-Z’s attempt to revive his extortion and defamation lawsuit against attorney Tony Buzbee, ending a legal counterattack the rapper launched after being named in a since-dismissed sexual assault complaint. In a 24-page unanimous ruling, the court found no evidence that Buzbee knowingly advanced false claims against the artist, whose legal name is Shawn Carter.
Associate Justice Anne Richardson wrote that the record did not show Buzbee accused Carter of raping Jane Doe while knowing the statements were false or with reckless disregard for their truth. To the contrary, declarations submitted by Buzbee indicated that investigations by his firm and a referral firm led him to subjectively believe the accusations. The appellate panel also held that Buzbee’s pre-suit demand letter was protected by the litigation privilege, framing it as a basic legal step rather than extortion.
Carter had argued that Buzbee sent two demand letters in late 2024 seeking money to resolve the matter privately, then publicly identified him after he declined to engage. The case initially appeared to gain traction, but Los Angeles County Judge Mark Epstein reconsidered after reviewing a recorded conversation between private investigators and Jane Doe in Alabama. The woman allegedly said, “It was more Diddy, but Buzbee brought Jay-Z into it.”
Buzbee said he expected the case to be dismissed and now intends to recover fees. The ruling reinforces that a demand letter tied to a high-profile allegation does not, by itself, constitute extortion under California law.
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