Mariah Carey Wins Dismissal of Brother's $20 Million Memoir Lawsuit

Caption: Mariah Carey performs during her Caution World Tour at the Ziggo Dome in Amsterdam. Credit: Filipe Vicente / Setor VIP / CC BY 2.5, via Wikimedia Commons.

Mariah Carey has won dismissal of the remaining claims in her brother’s $20 million memoir lawsuit, five years after he accused her of damaging his reputation. Morgan Carey’s lawyer says he plans to appeal.

According to reporting on the October 19 ruling, New York Supreme Court Justice Leslie A. Stroth found that Morgan had not sufficiently pleaded actual malice over the disputed passages. The $20 million was the sum he sought, not a court award.

The case grew out of The Meaning of Mariah Carey, published in 2020. Morgan disputed portrayals of drug dealing and imprisonment that remained at issue after an earlier ruling narrowed his complaint.

A memoir presented one sibling’s childhood account

Carey wrote the book with Michaela Angela Davis. The publisher’s excerpt frames the narrative as her effort to speak for the frightened child she remembers being, connecting childhood experiences to the adult public figure her listeners know.

Carey acknowledges in the book’s introduction that her account may differ from relatives’ memories. Morgan’s lawsuit, however, challenged specific portrayals of him as damaging and false.

Morgan sued in March 2021. His original complaint challenged several passages, including an alleged confrontation with their father and an allegation that he tried to obtain money through extortion, PEOPLE reported at the time.

He also said a professional project deal fell through because of his portrayal in the book. Those were claims of harm advanced in the litigation, not findings that the memoir caused a particular financial loss.

Two claims survived the first round

The case did not reach this week’s decision with every original allegation intact. In February 2022, Justice Barbara Jaffe dismissed most claims while allowing two defamation claims concerning drug dealing and imprisonment to continue, Law Commentary reported.

The claims against the publishers were dismissed. After Jaffe retired, the case was reassigned to Stroth, who considered the remaining dispute.

That sequence explains the disagreement now expressed by Morgan’s lawyer. He points to the earlier decisions permitting part of the case to proceed; the latest ruling concluded the actual-malice allegations were insufficient.

The disputed memoir references concerned conduct that Morgan denied. The dismissal does not turn those descriptions into judicial findings about his life.

The legal threshold was more than a disagreement over memory

Actual malice means publishing with knowledge that a statement is false or reckless disregard for whether it is true. It is a legal test about the publisher’s state of mind, not simply another term for hostility within a family.

Law Commentary reported that New York’s anti-SLAPP protections for speech on public-interest matters required a sufficient basis for that standard. Morgan argued that his sister valued the book’s commercial appeal over checking its contents and relied on anonymous or unverifiable sources.

Stroth found those assertions inadequate to establish that she knew the statements were false or recklessly disregarded their accuracy. That was the decisive defect in the remaining claims, as described in the reported ruling.

Mariah’s attorney, John Rosenberg, welcomed the outcome. He said the court recognized that the memoir addressed matters of public interest and framed the decision as protecting authors discussing subjects of public concern, according to Us Weekly’s account of his statement to Billboard.

Morgan’s attorney, Richard Altman, said he disagreed with the result and considered it inconsistent with the earlier rulings. “We intend to appeal it very soon,” he told Rolling Stone in a statement carried by Us Weekly.

Morgan’s attorney has announced plans to challenge the dismissal; the cited reporting did not confirm a filed appeal.

References: Mariah Carey Wins Dismissal of Brother’s $20M Defamation Lawsuit over Her Bestselling Memoir | Mariah Carey’s Brother’s $20 Million Defamation Lawsuit Over Her 2020 Memoir Is Dismissed | Mariah Carey’s Brother Sues Singer Over Her Memoir 1 Month After Their Sister Filed Separate Lawsuit | Mariah Carey Wins Five-Year Defamation Battle With Brother Over Memoir Allegations | The Meaning of Mariah Carey