The short version
- Judge Leslie Stroth dismissed Morgan Carey's defamation lawsuit against his sister Mariah, ruling he did not demonstrate she acted with actual malice or reckless disregard for the truth.
- The decision resolves a five-year legal battle stemming from allegations in The Meaning of Mariah Carey that portrayed Morgan as involved in drug dealing and violence.
- Morgan Carey’s legal team has indicated plans to appeal the ruling, while Mariah Carey’s attorney emphasized the broader implications for author protections on matters of public concern.
A New York judge has dismissed a defamation lawsuit filed by Morgan Carey against his sister, pop icon Mariah Carey, concluding a five-year legal dispute over claims made in her 2020 memoir. The ruling, issued by Judge Leslie Stroth, represents a complete victory for the singer and underscores the high legal threshold required to prove defamation in cases involving matters of public interest.
The litigation originated from Morgan Carey’s accusations that his sister falsely depicted him as a violent drug dealer and an abuser in her book, The Meaning of Mariah Carey. In the memoir, Mariah Carey described Morgan using harsh language, referring to him as a sometimes drug dealer who had been involved with the criminal justice system. She also labeled him her ex-brother, signaling a complete severance of their familial relationship.
Morgan Carey initially filed suit in New York’s Supreme Court in 2021, alleging that the memoir ruined his reputation and caused severe mental anguish. He denied any involvement in violence or drug trafficking and asserted he had no criminal record. His complaint specifically challenged claims that he sold cocaine during the 1980s and that he had physically abused their mother.
The case saw partial dismissal earlier in its lifecycle. In 2022, Judge Barbara Jaffe rejected fourteen of the sixteen original claims and dismissed all allegations against the book’s publisher, Macmillan. However, she allowed certain claims to proceed, noting that allegations regarding cocaine sales and physical abuse could potentially be defamatory if proven false and damaging.
Morgan Carey’s legal team appealed this partial dismissal in an amended complaint filed in January. They argued that the publication of the memoir directly caused financial harm, including the cancellation of a film project he co-wrote. The lawsuit sought more than $1.5 million in damages related to the lost film opportunity, along with unspecified compensation for emotional distress.
Judge Stroth’s recent decision overturned these remaining claims. She determined that Morgan Carey failed to establish that Mariah Carey knew her statements were false or acted with reckless disregard for the truth. This standard of actual malice is crucial in defamation cases involving public figures and matters of significant public interest. The judge noted that mere ill will between siblings was insufficient to meet this legal bar.
The dismissal highlights the robust protections afforded to authors discussing personal histories that intersect with public discourse. Mariah Carey’s attorney, John Rosenberg, stated that the court recognized the memoir’s address of significant public issues. He emphasized that the decision confirms broad protection for authors speaking out on matters of public concern, extending beyond this specific family dispute.
Despite the dismissal, the legal battle may not be entirely over. Richard Roth, one of Morgan Carey’s attorneys, indicated that he intends to appeal the ruling again. This suggests a continued effort to challenge the precedent set by Judge Stroth and potentially reopen the question of liability for the memoir’s contents.
This case follows another related legal action involving the Carey siblings. In 2021, Alison Carey, another sister, filed a $1.2 million defamation suit against Mariah over allegations in the same memoir. Those claims included accusations of physical abuse and sexual exploitation during their childhood. Alison Carey did not pursue that lawsuit further and passed away in 2024 at the age of 63.
The resolution of Morgan Carey’s lawsuit provides clarity on the limits of defamation claims against public figures regarding autobiographical works. It reinforces the principle that personal grievances, even when deeply felt, must meet stringent legal standards to override free speech protections in the context of published memoirs.
Sources behind this briefing
Go to the original reporting
- The Guardian US↗Mariah Carey wins dismissal of brother’s defamation lawsuit over her memoir
