Last Updated: August 21, 2026 
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Jay-Z’s attempt to revive his California lawsuit against attorney Tony Buzbee is now before a state appeals court after a three-justice panel heard arguments over the dismissal of his defamation and extortion claims.
The August 20 hearing focused in significant part on evidence that Carter says should have been considered before the trial court dismissed his claims, as well as whether Buzbee’s pre-litigation communications and public statements were protected under California law.
Why Was Jay-Z’s Lawsuit Against Tony Buzbee Dismissed?
Carter filed the California action against Buzbee and The Buzbee Law Firm after Buzbee represented a woman who alleged that Carter and Sean “Diddy” Combs sexually assaulted her when she was 13.
The woman’s federal civil lawsuit against Carter and Combs was voluntarily dismissed with prejudice in February 2025, meaning the same claims could not be refiled. Both Carter and Combs had denied the allegations. The voluntary dismissal did not result in a trial or judicial determination of the underlying sexual-assault allegations.
In the separate California case, Carter alleged that Buzbee and his firm had engaged in extortion and defamation through pre-litigation demand letters and public statements connected to the accusations.
Los Angeles County Superior Court Judge Mark H. Epstein granted Buzbee and his firm’s special motion to strike on June 30, 2025, under California’s anti-SLAPP statute. The trial court concluded that the conduct underlying Carter’s claims fell within the scope of California’s anti-SLAPP law and that Carter had not established the required probability of prevailing on the challenged claims.
California’s anti-SLAPP statute permits a defendant to seek early dismissal of certain claims arising from activity connected to the constitutional rights of petition or free speech unless the plaintiff can establish the required probability of prevailing on the claim.
Carter Challenges Exclusion of Private-Investigator Recordings
A central issue in Carter’s appeal involves recordings obtained by private investigators who interviewed the woman who had accused him.
Carter relied on the recordings as evidence supporting his claims against Buzbee. According to Carter’s account of the recordings, the woman said that Carter was not involved in the alleged assault and that Buzbee had pushed to include him in the earlier litigation.
The trial court ultimately excluded the evidence after questions arose over the circumstances in which the recordings were obtained and the identity of the investigators’ employer.
During the August 20 appellate argument, Carter’s attorney Jeremy B. Rosen argued that excluding the recordings materially affected the trial court’s evaluation of the case. He asked the appellate court to reverse the dismissal or allow limited proceedings to determine more about the investigators and the origin of the recordings.
Appeals Court Questions How the Recordings Were Obtained
The appellate panel questioned Carter’s attorneys about the private investigators and whether there was an adequate basis in the record to establish how their interview with the woman had been arranged.
Justice Stephen Goorvitch specifically raised concerns about the absence of clear information establishing who hired the investigators and how the recordings reached Carter’s legal team.
Carter’s attorney maintained that the trial court had accepted representations that Carter’s counsel was not responsible for arranging the interview and argued that further discovery could resolve the remaining questions about the evidence.
Buzbee’s Attorneys Defend the Trial Court’s Ruling
Attorneys representing Buzbee and his firm urged the appeals court to leave the dismissal in place.
Samuel A. Moniz, representing Buzbee and The Buzbee Law Firm, argued that the circumstances surrounding the interview undermined the reliability and admissibility of the evidence. He maintained that the woman felt pressured during her interaction with the private investigators.
According to Buzbee’s attorneys, the investigators’ interaction with the woman involved circumstances that could have affected the reliability of her statements, including alleged pressure to cooperate and recant her allegations against Carter.
The parties therefore dispute not only what significance should be given to the recorded statements, but whether the recordings should have been considered by the trial court at all.
Appeals Court Tentatively Leans Toward Affirming Dismissal
The California appellate court issued a tentative ruling in connection with the August 20 argument indicating that it was inclined to affirm the trial court’s dismissal under the anti-SLAPP law.
That tentative position is significant, but it is not the court’s final decision.
Carter’s attorneys used oral argument to challenge the tentative analysis and to argue that the treatment of the excluded evidence affected the outcome of the anti-SLAPP proceedings. Buzbee’s attorneys argued that the lower court reached the correct result.
What Happens Next?
The California appeals court must now issue its final decision after considering the parties’ briefs, the record from the trial court, and the arguments presented on August 20.
The court could affirm the dismissal, reverse all or part of the trial court’s ruling, or potentially direct further proceedings depending on its conclusions about the disputed legal and evidentiary issues.
For now, the June 30, 2025 dismissal remains the operative ruling, and Carter has not yet obtained a reversal or revival of his California claims. The appellate court’s tentative position should not be treated as a final judgment until its formal opinion is issued.
Disclaimer: This article is provided for general informational purposes only and reports on ongoing civil litigation involving Shawn Carter, Anthony Buzbee, and The Buzbee Law Firm. Allegations and arguments attributed to the parties are claims made in litigation and should not be treated as judicial findings unless expressly stated. The earlier sexual-assault lawsuit against Carter was voluntarily dismissed with prejudice without a trial or determination of liability. As of August 21, 2026, the California Court of Appeal has heard oral argument and indicated in its tentative ruling that it was inclined to affirm the dismissal, but it has not issued a final appellate decision resolving Carter’s appeal. The status of the case may change. This article does not constitute legal advice.
