Jay-Z’s California lawsuit against attorney Tony Buzbee was dismissed under California’s anti-SLAPP law, and an appeals court affirmed that decision on September 9, 2026. The appellate court later denied rehearing on October 1, leaving the judgment unchanged while clarifying that the trial court may consider new evidence and reconsider its ruling if appropriate. The decision did not determine whether the underlying assault allegations were true.
What happened in Jay-Z’s California lawsuit?
Shawn Carter, known as Jay-Z, sued Buzbee and the Buzbee Law Firm in California. The dispute followed demand letters Buzbee sent on November 5, 2024, on behalf of two clients identified in the appellate opinion as Jane Doe and John Doe. The letters alleged that Carter sexually assaulted them when they were minors at parties connected to Sean Combs, demanded mediation, and threatened lawsuits if he declined. These were allegations in the record, not findings that an assault occurred.
Carter declined mediation and filed his California action on November 18, 2024, initially alleging civil extortion and intentional infliction of emotional distress. He amended the complaint in December to add defamation claims based on statements Buzbee allegedly made in interviews and other communications.
On June 30, 2025, a Los Angeles Superior Court judge struck Carter’s claims under California’s anti-SLAPP law. The California Court of Appeal, Second Appellate District, Division Two, affirmed on September 9, 2026. On October 1, it denied Carter’s petition for rehearing. The appellate opinion is not certified for publication in the official reports. Read the appellate opinion; read the October 1 rehearing order.
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Why did the courts strike the claims?
California’s anti-SLAPP procedure has two stages. First, the court asks whether the challenged claims arise from protected activity. If they do, the plaintiff must show legally sufficient claims supported by evidence. The Court of Appeal agreed that Buzbee met the initial burden for the communications challenged in this case, then concluded Carter’s showing did not justify reviving the claims.
The demand letters and extortion claim
The appellate court treated the letters as protected prelitigation communications. They concerned contemplated litigation and proposed mediation, in a context the record showed involved litigation contemplated in good faith. It also concluded that the letters’ threat to file suit did not establish extortion as a matter of law on this record. See the court’s discussion of the demand letters and anti-SLAPP analysis.
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The defamation claim
The opinion considered whether the challenged statements referred to Carter and whether he made the required showing of actual malice as a public figure. The court found his showing insufficient to revive the defamation claims.
Justice Anne Richardson wrote: “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.” That statement addresses the record on actual malice; it is not a finding about whether the underlying accusations were true. Courthouse News coverage quoting the opinion.
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The recorded investigator interview
The Court of Appeal also upheld the trial court’s evidentiary treatment of a secretly recorded investigator interview with Jane Doe. It explained why circumstances surrounding the interview mattered to whether her unsworn statements were trustworthy and admissible at the anti-SLAPP stage. The ruling did not establish that the interview proved the accusations true or false. Read the opinion’s discussion of the evidence.
What the decision does—and does not—decide
The appellate court affirmed an order striking claims under anti-SLAPP procedure; it did not conduct a trial of the underlying assault allegations. The opinion’s factual account is based on pleadings and supporting and opposing affidavits. The dismissal therefore should not be described as proof either that the allegations were true or that they were false. The appellate opinion.
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The October 1 rehearing order did not reverse the affirmance or change the judgment. It clarified that the trial court may order discovery and reconsider its prior ruling based on new evidence if it considers that appropriate. The order does not say that discovery or reconsideration has actually been ordered. Read the rehearing order.
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.How this differs from Jay-Z’s separate federal case
Carter also brought a separate federal action involving Jane Doe and other defendants, asserting malicious prosecution, abuse of process, civil conspiracy, and defamation. A federal order dated March 31, 2026, transferred that case from the Southern District of Alabama to the Southern District of New York. Motions to dismiss and motions concerning pseudonyms remained pending for the receiving court under that order. This is not the California lawsuit against Buzbee, and its status does not change the California appeal result. Read the federal transfer order.
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California case timeline
| Date | Event |
|---|---|
| November 5, 2024 | Buzbee sent demand letters on behalf of Jane Doe and John Doe. |
| November 18, 2024 | Carter filed the California action, initially alleging civil extortion and intentional infliction of emotional distress. |
| December 2024 | Carter amended his complaint to add defamation claims. |
| June 30, 2025 | The Los Angeles Superior Court struck the claims under anti-SLAPP law. |
| September 9, 2026 | The California Court of Appeal affirmed the order. |
| October 1, 2026 | The Court of Appeal denied rehearing and clarified that the trial court may consider new evidence and reconsider if appropriate; the judgment did not change. |
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