Mariah Carey wins dismissal of brother's memoir defamation lawsuit

Mariah Carey has won dismissal of the defamation lawsuit brought by her older brother Morgan Carey over her 2020 memoir The Meaning of Mariah Carey.

Judge Leslie A. Stroth threw out the case in its entirety in an order issued on Oct. 19. She ruled that Morgan Carey had failed to sufficiently plead actual malice, the legal test that requires a claimant to show a writer knew a statement was false or acted with reckless disregard for whether it was true. Billboard

The surviving claims centred on two passages. One described Morgan Carey selling “powdered party favors” to clubgoers in the 1980s. The other said he had “been in the system.” The court treated those lines as suggestions that he had sold cocaine and spent time in prison.

Stroth found those readings were not enough on their own. Without facts supporting actual malice by Mariah Carey, the claims could not proceed. Defamation law sets a high bar for public figures and matters of public interest, and the judge said that bar had not been met here.

Lawyers for both sides responded quickly. John Rosenberg, acting for Mariah Carey, said she was gratified that the court had recognised the memoir as addressing issues of significant public interest. Richard Altman, acting for Morgan Carey, said he plans to appeal the dismissal.

The dispute dates to March 2021. Morgan Carey sued after The Meaning of Mariah Carey reached No. 1 on the New York Times bestseller list. His initial filing pointed to eight sections of the book, including a description of a fight between his father and brother and a claim that he had sketchy contacts in the music industry.

Much of that case fell away in 2022. Judge Barbara Jaffe dismissed many of the claims but allowed the two passages about drugs and prison time to continue. That ruling also ended the claims against the book’s publishers. Reuters

The file was later reassigned to Stroth after Jaffe retired. Court records show the action was commenced on March 3, 2021, and originally included claims for defamation, defamation per se and injurious falsehood, a claim for false statements that cause economic harm.

For readers coming to the story now, this decision closes the long-running memoir fight at trial-court level, subject to appeal. It came one month after a separate $1.25 million action filed by the singer’s older sister Alison Carey, who alleged emotional distress arising from the memoir. Reuters