A New York state court has dismissed the remaining defamation claims Morgan Carey brought against his sister Mariah Carey over her 2020 memoir, closing out a legal battle that stretched across five years and sought more than $20 million in damages. Justice Leslie A. Stroth ruled that Morgan Carey failed to establish that his sister acted with actual malice, a required showing in defamation cases involving matters of public concern.
According to Rolling Stone, Stroth found that Morgan Carey offered no proof that his sister knew her statements were false or recklessly disregarded the truth when she published The Meaning of Mariah Carey. The judge wrote that the plaintiff “fails to provide any proof that [Mariah] made such statements with knowledge of their falsity or with reckless disregard for the truth.” Stroth also found that Morgan Carey's allegation of ill will did not satisfy the pleading requirement for actual malice.
Morgan Carey filed the lawsuit on May 28, 2021, alleging that the bestselling memoir portrayed him as violent and accused him of trafficking cocaine, which the suit referred to as “powdered party favors.” He claimed the alleged defamation caused damages believed to exceed $20 million. As TheWrap reported, Morgan Carey said in the lawsuit that he felt sorrowful and disappointed by what he called his sister's betrayals and malicious falsehoods, rather than angry, and insisted he was not envious of her success and had always wished her well.
A Case That Narrowed Over Five Years
The lawsuit had already been whittled down significantly before this latest ruling. The same litigation moved from a partial dismissal in 2022 to the dismissal of all remaining claims this year, according to Newsbeep. Back in 2022, Judge Barbara Jaffe dismissed many of Morgan Carey's claims but allowed those tied to two specific passages in the book to proceed, per the same account from Billboard.
That earlier round of rulings also cleared everyone else named in the case. The court dismissed all the defamation claims against the publisher defendants and six of the eight defamation claims against Mariah Carey herself, according to a legal analysis from Loeb & Loeb. Those publisher-side defendants included Macmillan Publishers Ltd., Macmillan imprint Andy Cohen Books, and Mariah Carey's memoir co-author Michaela Angela Davis, the firm noted.
Public Interest Shielded the Memoir's Claims
Earlier proceedings in the case treated subjects raised in the memoir, including domestic violence, child abuse and Mariah Carey's career, as matters of legitimate public interest under New York's anti-SLAPP statute, Loeb & Loeb explained. That framework requires plaintiffs suing over statements on public-interest topics to clear the higher bar of proving actual malice, the same hurdle Morgan Carey's claims failed to clear in Stroth's ruling.
Mariah Carey's attorney, John Rosenberg, told Rolling Stone that his client was gratified the court recognized her memoir addressed significant public-interest issues and dismissed the defamation claims in their entirety. Rosenberg said the ruling confirms that authors must be afforded broad protection when they speak out on matters of public concern.
Brother's Attorney Vows an Appeal
Richard Altman, who represents Morgan Carey, told Rolling Stone that he and his client intend to appeal the decision very soon. Per TheWrap, Altman also disagreed with the court's decision and called it inconsistent with prior rulings issued earlier in the case.
The memoir at the center of the dispute reached the top of The New York Times bestseller list in October 2020, according to Forbes. Mariah Carey was not the only sibling to face such a lawsuit over the book: her older sister, Alison Carey, separately sued her for $1.25 million in February 2021 over alleged false claims in the same memoir, Forbes reported. As of a February 2022 report from the New York Daily News, that separate lawsuit from Alison Carey, which the outlet described her calling the book “vindictive,” was still pending.
