Jay-Z’s Defamation Lawsuit Against Lawyer Who Filed Rape Case Faces Skeptical Appeals Court

A California appeals court is leaning towards affirming the dismissal of Jay-Z’s extortion and defamation lawsuit against personal injury attorney Tony Buzbee.

A panel of state appellate judges heard arguments on Thursday (Aug. 20) in Jay-Z’s Los Angeles case against Buzbee, who filed a short-lived 2024 lawsuit accusing the rap icon (Shawn Carter) of raping a 13-year-old girl alongside Sean “Diddy” Combs decades earlier. Jay-Z vehemently denied this and then went on the offensive, suing Buzbee in two different forums for allegedly fabricating the claims in pursuit of money and publicity.

The rapper’s California case relied heavily on a recorded interview between private investigators and the anonymous rape accuser, known as Jane Doe, in which the woman supposedly admitted the claims were false and that Buzbee pressured her to lie. Judge Mark H. Epstein ruled last July that this interview is inadmissible under the legal hearsay rule — and as a result, he threw out the case due to insufficient evidence at the outset. Jay-Z appealed.

As oral arguments began Thursday, three appellate judges announced that their tentative thinking was to affirm Judge Epstein’s dismissal. Judge Stephen Goorvitch voiced concerns about the origin of this recording, since it’s not clear who hired the private investigators who spoke to Doe. Jay-Z’s attorneys say it wasn’t them.

“My concern is a plaintiff’s lawyer shows up in court and says, ‘Magically this interview has been dropped in my lap, I had nothing to do with it,’” said Judge Goorvitch. “We have no information about where this came from. It looks highly suspicious that somehow, somebody talked to Mr. Buzbee’s client directly.”

Judge Anne Richardson agreed that the recording is “not a reliable statement,” since Doe seemed to merely be giving yes-or-no answers to leading questions from investigators. A lawyer representing Buzbee, Samuel Moniz, went a step further by arguing that investigators threatened to publicly reveal Doe’s identity unless she cooperated.

“To say these circumstances are inherently intimidating is an understatement,” said Moniz during the hearing. “If you listen to the recording, her voice is trembling. She’s frightened. She’s totally caught off guard.”

Jay-Z’s lawyer, Jeremy Rosen, tried to sway the appeal judges into changing their minds and reviving the case for further litigation. He said that full evidence discovery — including the exchange of documents and witness testimony — should be conducted before it’s decided whether or not Buzbee pressured Doe to fabricate rape claims.

“At trial, [Jane Doe] will either testify consistently with this investigation or she won’t, and the jury will then get to decide if she’s credible and what the ultimate facts are,” said Rosen. “Due process demands at least the opportunity to have limited discovery.”

The appellate court took the matter under consideration for a written ruling.

While Jay-Z waits for a decision on the future of the California case, he’s still pursuing a separate malicious prosecution suit against both Buzbee and Doe in federal court. That matter was recently transferred from Alabama to New York, and Buzbee is scheduled to file a key motion to dismiss next month.