California Appeals Court Signals Dismissal of Jay-Z's Lawsuit Against Attorney Tony Buzbee Will Stand

A California appeals court appears ready to uphold the dismissal of Jay-Z's extortion and defamation lawsuit against Houston attorney Tony Buzbee, after three appellate judges expressed tentative agreement with a lower court's decision to throw the case out.

During oral arguments on 20 August, the three-judge panel announced a tentative leaning to affirm the ruling issued last July by California Superior Court Judge Mark H. Epstein, who dismissed the case at its outset for insufficient evidence (Billboard).

The dispute stems from a now-dismissed 2024 lawsuit filed by Buzbee that accused Jay-Z — born Shawn Carter — of raping a 13-year-old girl alongside Sean "Diddy" Combs. Jay-Z responded by suing Buzbee in two separate forums, alleging the attorney fabricated the rape accusations in pursuit of money and publicity.

Jay-Z's California case hinged on a recorded interview between private investigators and the anonymous accuser, identified as Jane Doe, in which she purportedly admitted the claims were false and said Buzbee had pressured her to lie. Judge Epstein ruled that recording inadmissible under the hearsay rule — the legal principle that bars second-hand statements from being used as evidence — and dismissed the case before it could proceed to discovery, the pre-trial phase where each side gathers evidence from the other.

The appellate judges voiced specific concerns about the recording. Judge Stephen Goorvitch noted that it remains unclear who hired the private investigators who spoke with Jane Doe, and that Jay-Z's own attorneys have said it was not them. Judge Anne Richardson agreed the recording was unreliable, pointing out that Jane Doe appeared to be giving only yes-or-no answers to leading questions from the investigators.

Buzbee's lawyer, Samuel Moniz, argued during the hearing that the investigators had threatened to publicly reveal Jane Doe's identity unless she cooperated. Jay-Z's lawyer, Jeremy Rosen, urged the panel to revive the case and allow discovery to proceed before deciding whether Buzbee had pressured Jane Doe to fabricate the rape claims.

The court took the matter under submission and will issue a written ruling in due course.

The California dismissal was initially granted on First Amendment grounds, a defence successfully mounted by law firm Sheppard Mullin on Buzbee's behalf (Houston Public Media; Sheppard Mullin).

The California case is not the only legal front. Jay-Z is pursuing a separate malicious prosecution lawsuit — a claim that someone pursued a legal action without proper grounds — against both Buzbee and Jane Doe in federal court. That matter was recently transferred from Alabama to New York. In January 2025, Jay-Z also sought court sanctions against Buzbee, accusing him of multiple inaccuracies in the rape complaint and of failing to investigate the allegations before filing them (Reuters).

For now, the California appellate panel's tentative position leaves Jay-Z without one of his key legal vehicles against the attorney who brought the short-lived rape accusation. A formal written ruling will determine whether the dismissal is final or whether a pathway to revive the case exists.