A California appeals court ruled that lawyer Tony Buzbee did not act maliciously when he briefly defended the woman who claimed that Jay-Z and Sean Combs sexually assaulted her at a 2000 MTV Video Music Awards afterparty.
Courtesy of Tony Buzbee
A California appeals court has rejected Jay-Z’s appeal to revive a defamation lawsuit against Houston lawyer Tony Buzbee.
The California appeals court ruled that lawyer Tony Buzbee did not act maliciously when he briefly defended the woman who claimed that Jay-Z and Sean Combs sexually assaulted her at a 2000 MTV Video Music Awards afterparty.
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“The record contains no evidence Buzbee accused Carter of raping Jane Doe while knowing those statements to be false or with reckless disregard as to whether they were true,” Associate Justice Anne Richardson wrote in the unanimous ruling from California’s Second Appellate District. “To the contrary, Buzbee submitted declarations showing his firm’s and investigations led him to subjectively believe in the truth of the accusations.”
The court also ruled that Buzbee’s demand letters sent to Jay-Z before he was officially named in the lawsuit were in “good faith.”
“Sending a basic demand letter prior to filing suit is not and will never be ‘extortion,’” Buzbee said in a statement to Rolling Stone on Thursday. “The plaintiff distorted the truth and twisted facts. I expected the case to be dismissed and now that it has been, I look forward to recovering my every penny of my fees and expenses.”
Jay-Z’s lawsuit against Buzbee was initially dismissed in July 2025
Rapper Jay-Z during the 2026 FIFA World Cup Round of 16 match between Brazil and Norway at Metlife Stadium on July 5, 2026, in East Rutherford, New Jersey, United States.
ANP/ANP via Getty Images
In July 2025, Los Angeles County Judge Mark Epstein dismissed the defamation suit brought against Buzbee by Jay-Z, real name Shawn Carter. The defamation suit alleged Buzbee attempted to use the lawsuit he to spread false claims against him.
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On February 14, 2025, Jane Doe dismissed the lawsuit against Carter with prejudice in exchange for Carter’s assurance that neither he nor his representatives would get in touch with her. The dismissal came after investigators, at the behest of Jay-Z, confronted Jane Doe at her home in Alabama. The confrontation resulted in a recording that was submitted to the California court, where Jane Doe said Jay-Z did not rape her and that Buzbee pushed her to sue.
The recording’s relevance and admissibility were contested by Buzbee’s attorneys. The court stated that the exchange was “not as clear as either party would like” and mentioned Jane Doe’s subsequent claim that the investigators had harassed and threatened her.
The demands Buzbee sent to Jay-Z in 2023 were deemed in “good faith”
Jay-Z claimed Buzbee sent two demand letters in Nov. 2023 threatening to spread the claims unless the rapper agreed to settle out of court. Jay-Z claimed weeks later that he was only named by Buzbee as the previously unidentified John Doe co-defendant in the Jane Doe’s lawsuit after he refused to pay a secret settlement.
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In his 2025 ruling, Epstein said the demand letters did not contain a “demand for a particular sum of money” or any promises to refrain from going to law enforcement if a sum of money isn’t paid.
“While it is true that the alleged conduct here constitutes criminal activity, defendants fall well short of threatening to go to the police unless Carter pays up,” Epstein said. Epstein wrote in a 65-page ruling.
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Although he was not “wholly satisfied” with his decision to completely dismiss Carter’s extortion and defamation case, Epstein made an effort to weigh the conflicting interests involved. Epstein came to the conclusion that he would wait for the Court of Appeals to determine if his decision was “right or wrong.”
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“The case they filed against me was s–t,” Buzbee told Chron at the time. “I predicted it would be dismissed, and it finally has been. We will continue to do our important work and won’t be deterred.”
Jay-Z is still suing Buzbee separately, despite the decision on Wednesday. Buzbee is facing a pending malicious prosecution case in New York.