Nancy Dillon
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Mariah Carey and brother Morgan Carey in 1991. WireImage Mariah Carey has prevailed in a five-year legal battle with her brother, winning the dismissal of his remaining claims that she defamed him in her bestselling 2020 memoir, The Meaning of Mariah Carey.
In a ruling issued Monday and obtained by Rolling Stone, Justice Leslie A. Stroth of the New York State Supreme Court found that Morgan Carey failed to establish that his superstar sister acted with “actual malice” when making the statements he challenged.
Morgan claimed in his lawsuit that his sister had damaged his otherwise “excellent and spotless reputation” by portraying him as violent, accusing him of trafficking “powdered party favors” (a reference to cocaine), and describing him as having “behavioral problems” during childhood. He claimed Mariah had relied on their late mother as a source for some of the material and was more concerned with the memoir’s commercial success than with verifying the accuracy of her claims. He said his damages were “believed to exceed $20 million.”
But the judge found that Morgan could not establish actual malice simply by pointing to the deterioration of his relationship with his famous sibling. Under New York anti-SLAPP law, a plaintiff must show that a defendant made a false statement knowing it was false or with reckless disregard for the truth.
“Plaintiff has not sufficiently pleaded actual malice on the part of [Mariah],” Justice Stroth wrote. “Plaintiff fails to provide any proof that [Mariah] made such statements with knowledge of their falsity or with reckless disregard of their falsity or with reckless disregard for the truth. While plaintiff alleges that [Mariah] demonstrates ill will towards her brother, such statement is insufficient, and plaintiff has not satisfied the pleading requirement for actual malice.”
In a statement to Rolling Stone, Mariah’s lawyer, John Rosenberg, said that the singer “is gratified that the court recognized that her memoir addresses significant issues of public interest and dismissed her brother’s defamation claims in their entirety.”