A California appeals court has rejected Jay-Z’s attempt to revive an extortion and defamation lawsuit against lawyer Tony Buzbee over a since-withdrawn case accusing the rapper of raping a 13-year-old girl.
The three-judge panel upheld a lower court’s decision dismissing claims brought by Jay-Z, whose real name is Shawn Carter, after concluding that Buzbee’s demand letters and other disputed communications were protected because they were connected to anticipated litigation.
The ruling does not determine whether the underlying rape allegation was true. Jay-Z has emphatically denied the accusation, while the woman who made it voluntarily dismissed her lawsuit with prejudice in February 2025.
Court rejects extortion argument
The dispute began after Buzbee sent letters to Carter’s representatives in 2024 alleging that the music mogul had sexually assaulted minors and proposing confidential mediation before filing a public lawsuit.
Carter argued that the letters represented an attempt to force him to pay money by threatening to destroy his reputation through allegations Buzbee allegedly knew were false.
Buzbee later amended an existing lawsuit against Sean “Diddy” Combs to identify Carter as a second defendant. The anonymous woman claimed that Carter and Combs raped her at an afterparty following the 2000 MTV Video Music Awards when she was 13.
Carter accused Buzbee of using the threatened publicity surrounding the allegation as leverage to extract a settlement.
The appeals court nevertheless agreed with Los Angeles Superior Court Judge Mark H. Epstein that the communications did not meet California’s legal threshold for extortion.
The judges concluded that offering Carter an opportunity to resolve the dispute privately before pursuing litigation could not support an extortion claim merely because the threatened lawsuit involved an allegation capable of causing severe reputational damage.
Defamation claim protected by litigation privilege
Carter also accused Buzbee of defamation, maintaining that the lawyer knowingly promoted a fabricated allegation.
However, the court found that the disputed statements were protected by California’s litigation privilege, which generally shields communications made during, or in serious contemplation of, judicial proceedings.
The protection is intended to allow lawyers and parties to communicate freely when preparing or pursuing legal claims without facing separate lawsuits over those statements.
Carter’s lawyers argued that the privilege should not protect what they described as a calculated campaign based on allegations that had not been properly investigated.
The appeals court was not persuaded, affirming the dismissal rather than allowing the extortion and defamation claims to proceed towards trial.
The ruling does not amount to a finding that Buzbee’s allegations were accurate or that he acted appropriately. It addresses whether Carter’s California claims could legally proceed.
Accuser withdrew lawsuit after inconsistencies emerged
Questions about the woman’s account intensified after she acknowledged inconsistencies during an interview with NBC News.
Among the disputed details were her description of how she travelled to and from the alleged party and her claim that she spoke to musician Benji Madden at the event. Madden was reportedly touring elsewhere at the time.
Her father also said he did not remember collecting her after the alleged incident, as she had claimed.
Buzbee said the inconsistencies did not necessarily disprove the central allegation. Carter maintained that he had never met the woman and described the case as a blackmail attempt.
The woman withdrew her lawsuit with prejudice in February 2025, meaning that particular case cannot be refiled. No settlement was announced.
Carter subsequently filed another lawsuit in Alabama against the woman, Buzbee and fellow lawyer David Fortney, accusing them of malicious prosecution, abuse of process, conspiracy and defamation. That action is separate from the California case affected by the appeals court’s decision.
Buzbee has denied fabricating the accusation or coercing his former client and has characterised Carter’s legal actions as attempts to intimidate lawyers representing alleged sexual-assault victims.
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