Judge Dismisses Morgan Carey’s Defamation Suit Over Mariah Carey Memoir

Key points

• Judge Leslie A. Stroth ruled that Morgan Carey did not meet the legal standard of 'actual malice' required to sue a public figure for defamation.
• The lawsuit stemmed from passages in Mariah Carey’s 2020 memoir, 'The Meaning of Mariah Carey,' which alleged Morgan sold cocaine and served prison time.
• Mariah’s attorney, John Rosenberg, stated the ruling confirms broad protections for authors speaking on matters of public interest.
• Morgan’s attorney, Richard Altman, announced plans to appeal the dismissal, citing inconsistencies with prior rulings in the case.
• The case had previously been partially dismissed by Judge Barbara Jaffe in 2022 but was reassigned to Judge Stroth after Jaffe retired.

Background

The legal dispute began in 2021, shortly after Mariah Carey’s memoir reached the New York Times bestseller list. Morgan Carey initially alleged defamation in eight parts of the book, including claims about a family fight and his contacts in the music industry. While Judge Jaffe dismissed most claims in 2022, she allowed two specific allegations regarding drug sales and incarceration to proceed. The case remained in litigation for several years before Judge Stroth issued the final dismissal on October 19, 2026.

Why it matters

The ruling reinforces the legal standard that public figures must prove 'actual malice' to succeed in defamation cases, offering significant protection for authors and journalists addressing matters of public interest. It also concludes a high-profile family dispute that had dominated legal news for five years.

What to watch

Morgan Carey’s attorney, Richard Altman, has indicated he will appeal the dismissal. The next steps will depend on whether the appellate court upholds Judge Stroth’s interpretation of the 'actual malice' standard in this context.