Jay-Z’s Action Over Attorney Demand Letter Citing Sex-Abuse Claims Is SLAPP

Friday, September 11, 2026

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Jay-Z’s Action Over Attorney Demand Letter Citing Sex-Abuse Claims Is SLAPP—C.A.

Opinion Says Litigation Privilege Shields Purportedly Extortionary Note, Rejects View That No Good Faith Basis for Action That Named Rapper as Abuser Before Suit Was Dropped

By Kimber Cooley, associate editor

Depicted is the cover art for Jay-Z’s 1997 album “In My Lifetime Vol. 1.” On Wednesday, Div. Two of this district’s Court of Appeal upheld an order specially striking a complaint accusing a Texas lawyer of attempting to extort the rapper by demanding mediation over claims that the recording artist participated in sexual assaults in the wake of sex-trafficking allegations against fellow-hip-hop star Sean ‘Diddy’ Combs.

Div. Two of this district’s Court of Appeal has upheld an order granting a special motion to strike a complaint filed by the 25-time Grammy-Award winning rapper Shawn Carter—who performs under the name “Jay-Z”—that accuses a Texas law firm of attempting to extort the artist.

It allegedly did so by way of a demand letter that cited claims by an anonymous client who purportedly said the star participated in “freak-off” parties hosted by now-disgraced Sean “Diddy” Combs.

The letter was sent by Houston-area attorney Anthony G. Buzbee who began representing victims of Combs’ purported sex-trafficking scheme after a federal indictment was filed in September 2024, alleging that the rapper had hosted events at which party-goers were coerced into performing sex acts. Last year, Combs was convicted of two counts of transportation to engage in prostitution and sentenced to 4 years in prison.

Buzbee said that two clients, identified only as Jane and John Doe, also identified Carter as a participant in sexual assaults at the parties. On Nov. 5, 2024, Buzbee sent “Mediation Demand” letters to Carter on behalf of the Doe parties, claiming that he sexually assaulted both while they were underaged teenagers and asserting that they would sue if the star refused to meet to discuss their claims.

Complaint Filed

Carter filed a complaint against the firm two weeks after the letters were sent, asserting claims for civil extortion and intentional infliction of emotional distress. He amended the pleading one month later to add a defamation cause of action based on media reports attributing statements that Carter might soon face “a criminal complaint” and “a civil suit alleging sexual assault” to Buzbee.

Justice Anne Richardson authored Wednesday’s unpublished opinion, saying the claims were covered by California’s anti-SLAPP law, found at Code of Civil Procedure §425.16, which shields a party from liability “from any act…in furtherance of the person’s right of petition or free speech…unless the court determines that the plaintiff has established that there is a probability that the plaintiff will prevail on the claim.”

Agreeing with Los Angeles Superior Court Judge Mark H. Epstein, who granted the anti-SLAPP motion in June of last year, that the demand letters amounted to protected speech, she wrote:

“Carter argues Buzbee did not meet his first-step burden because the record, construed in his favor, shows the Demand Letters were not made in good faith anticipation of litigation. But at the first step, the only issue is whether Buzbee made a prima facie case that the activity underlying Carter’s claims is statutorily protected [under the litigation privilege found at Civil Code §47], not whether his actions were ultimately lawful….Buzbee met this burden.”

As to whether the plaintiff had established the requisite probability of prevailing, she acknowledged case law establishing that statements that amount to extortion as a matter of law are not covered by §47 but said:

“Buzbee did not concede he engaged in extortionate conduct, and Carter submitted no evidence to prove illegality conclusively.”

Dismissal of Litigation

Richardson noted that “Carter contends a jury could infer John and Jane Doe did not seriously consider suing him because John Doe never sued and Jane Doe ultimately dismissed” litigation naming Carter as an abuser. However, she opined:

“But this does not necessarily show John and Jane Doe did not genuinely contemplate suing.”

The jurist continued:

“Carter argues it can be inferred that Jane Doe’s demand letter was a negotiating tactic because when Buzbee sent the ‘pre-suit demand,’ Jane Doe had already filed the New York Action accusing [an unnamed celebrity who she later identified as Carter] of sexual assault. Although Carter claims this was done to ‘goad’ him ‘into making a pay-off…’ and to leave open the option of extorting others, he fails to point to any evidence to support this interpretation of Jane Doe’s actions.”

Addressing to the defamation cause of action, she pointed out that “Carter does not dispute it arises from protected activity” and that “[w]hen the plaintiff is a public figure, which Carter does not dispute he is, he must also” show that the purportedly defamatory statement was made with “actual malice.” Based on the standard, she remarked:

“[T]he trial court correctly concluded Carter failed to show Buzbee made those statements with actual malice. The record contains no evidence Buzbee accused Carter of raping Jane Doe while knowing those statements to be false or with reckless disregard as to whether they were true. To the contrary, Buzbee submitted declarations showing his firm’s…investigations led him to subjectively believe in the truth of the accusations.”

Statements to Investigators

The plaintiff had asked Epstein to consider statements made by Jane Doe to Carter-affiliated “investigators” who visited her at her Alabama home in February 2025 and surreptitiously recorded their conversation with her. They said they were there to “help her” and promised that she would remain anonymous and left alone if she cooperated.

She purportedly told them that she had informed Buzbee that Carter was present at a party when she was raped by Combs but did not participate in the assault but that attorneys with Buzbee’s firm told her that she would receive a payout if she made the accusation against Carter.

Rejecting Carter’s assertion that even if the statements were hearsay, the court should have lifted the discovery stay imposed under §425.16(g) to allow him to depose Jane Doe and Buzbee, she noted that the request was not timely made in the trial court and that Epstein had “reasonably concluded depositions would be inappropriate because Jane Doe and Buzbee already presented sworn testimony on the subject of Carter’s proposed inquiry.”

Under those circumstances, she concluded that there was no abuse of discretion, saying:

“Discovery may not be obtained under the anti-SLAPP statute ‘merely to “test” the opponent’s declarations.’…

“[E]ven if Carter had been given an opportunity to depose Jane Doe and Buzbee, the attorney-client privilege would foreclose him from asking them about their communications.”

The case is Carter v. The Buzbee Law Firm, B347898.

Carter was represented by David R. Carpenter, Collin P. Wedel, and Madeleine Joseph of Sidley Austin LLP together with Felix Shafir, Mark A. Kressel, Jeremy B. Rosen, Marshall Grasty of the Burbank firm Horvitz & Levy LLP. Acting for the defendants were Camille M. Vasquez, J. Randall Boyer, Samuel A. Moniz, Melissa Medhat Mikail, and Valerie E. Alter of the Costa Mesa and Los Angeles offices of Sheppard, Mullin, Richter & Hampton LLP.