Sean Combs’s April 2024 effort to dismiss statutory “revenge porn” claims did not end Joi Dickerson-Neal’s civil lawsuit. The motion was overtaken by an amended complaint; a later motion challenging the remaining claims was denied in February 2025, according to a case-status report. The case then proceeded on common-law claims, not the original statutory claims.
What Dickerson-Neal alleged
Dickerson-Neal filed her civil suit in New York County Supreme Court. A copy of the complaint received on November 23, 2023, alleges that Combs sexually assaulted her on January 3, 1991, when she was 19, recorded the incident, and later showed the recording to others without her consent. These are allegations, not established findings; the complaint copy itself cautions that the clerk had not reviewed and approved it when printed. Complaint copy, NYSCEF Doc. No. 1
Combs denied the allegations. The Associated Press reported that his representatives said they “vehemently deny” what they called “numerous false, offensive, and salacious accusations.” Associated Press, April 27, 2024
Why Combs sought dismissal of the statutory claims
On April 26, 2024, Combs’s lawyers moved to dismiss certain statutory claims, including claims under New York’s revenge-porn and human-trafficking laws. Their argument was that those statutes were enacted after the alleged 1991 conduct and could not be applied retroactively. The Los Angeles Times also reported the defense argued that the company defendants did not exist at the time of the alleged events. Associated Press, April 27, 2024; Los Angeles Times, April 29, 2024
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This was a legal argument about which causes of action could proceed under statutes enacted later. It was not a court determination about whether an assault, recording, or sharing took place.
How the two dismissal motions differ
| Motion | Claims and pleading at issue | Reported result |
|---|---|---|
| April 2024 motion | Statutory claims in the original complaint, including revenge-porn and human-trafficking claims | Mooted after the parties stipulated to an amended complaint |
| Later motion | Common-law claims in the amended complaint: assault, battery, and intentional infliction of emotional distress | Denied February 13, 2025, according to the case-status report |
The procedural history is reported by Diddy Docket, a docket-focused case report. Diddy Docket, August 31, 2026
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What remained after the amended complaint
The parties’ stipulation made the first motion moot. The amended complaint dropped the statutory claims at issue in that motion and continued against Combs alone, alleging common-law assault, battery, and intentional infliction of emotional distress. The corporate defendants were dismissed with prejudice, according to the case-status report. Diddy Docket, August 31, 2026
The later denial meant those amended claims could continue past the motion-to-dismiss stage. It did not decide whether Dickerson-Neal’s allegations were true. The case report attributes this sentence to the court’s February 13, 2025 decision: “is extreme and outrageous, and if true would be intolerable for a civilized community.” The conditional wording matters: the reported statement addresses what the allegations would mean if true, not whether the alleged events were proved. Diddy Docket, August 31, 2026
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Latest reported status
Diddy Docket reports that Combs answered the amended complaint in March 2025 and that the parties submitted a proposed protective order for discovery in August 2026. That is the latest status reflected in the cited reporting; it does not establish the outcome of the case or any later development. Diddy Docket, August 31, 2026
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