A judge in New York, United States, dismissed Morgan Carey’s defamation lawsuit against his sister Mariah Carey on Monday (Oct. 19). The case concerned passages in her 2020 memoir The Meaning of Mariah Carey that suggested he had sold cocaine and done prison time.
Judge Leslie A. Stroth ruled that Morgan Carey did not meet the standard required under New York law for defamation claims against a public figure: actual malice, meaning knowledge of falsity or reckless disregard for the truth.
“The Court finds that Plaintiff has not sufficiently pleaded actual malice on the part of Defendant. Plaintiff has alleged that Defendant was more concerned with the ‘commercial viability’ of her memoir than verifying the truth of her statements, and that Defendant’s sources for such statements are anonymous and/or unverifiable. Notably, Plaintiff fails to provide any proof that Defendant made such statements with knowledge of their falsity or with reckless disregard for the truth.”
Mariah Carey’s attorney, John Rosenberg, said the singer was “gratified” by the ruling. “Ms. Carey is gratified that the Court recognized that her memoir addresses significant issues of public interest and dismissed her brother’s defamation claims in their entirety,” Rosenberg said.
Rosenberg added: “Ms. Carey believes the importance of the Court’s decision goes well beyond her own interests in this particular litigation, as it confirms that authors must be afforded broad protection when they speak out on matters of public concern.”
Morgan Carey’s attorney, Richard Altman, said he plans to appeal. “We respectfully disagree with today’s decision as being inconsistent with prior rulings in the case,” Altman said.
How the case unfolded#
Morgan Carey first sued Mariah Carey in 2021, a few months after The Meaning of Mariah Carey reached No. 1 on the New York Times bestseller list. He initially alleged defamation in eight parts of the book, including a passage describing a “vicious fight between my father and brother” and another stating he had “sketchy contacts in the music industry.”
In 2022, the first judge assigned to the case, Judge Barbara Jaffe, dismissed many of those claims. She allowed the case to proceed on two passages:
- one in which Mariah Carey wrote that her brother sold “powdered party favors” to clubgoers in the 1980s
- another claiming he had “been in the system.”
The case then spent several more years in litigation. Morgan Carey reasserted dismissed claims in an amended complaint. After Judge Jaffe retired, the lawsuit was reassigned to Judge Stroth.
Actual malice focus#
Judge Stroth’s Monday opinion took a fresh look at the case. The judge focused on actual malice, which had not been the focus of Mariah Carey’s first motion to dismiss in 2022. Judge Stroth determined that Morgan Carey’s failure to meet this standard should end the entire case.
