Mariah Carey Wins Dismissal of Brother Morgan Carey’s $20 Million Defamation Lawsuit Over Her Memoir
A New York judge has dismissed the remaining claims in Morgan Carey’s defamation lawsuit against his sister, Mariah Carey, over her 2020 memoir, The Meaning of Mariah Carey. On Monday, October 19, 2026, Justice Leslie A. Stroth of the New York State Supreme Court, New York County, ruled that Morgan had not sufficiently pleaded actual malice, the legal standard that applies to this kind of case. His lawyer has said he plans to appeal.
The ruling is not a jury verdict, and it is not a finding that every statement in the memoir is true. It is a court deciding that the claims, as pleaded, did not meet the required legal test.
This is a private lawsuit between two people. It is not a class action, and there is no claim form, fund or public compensation program.
Quick Facts: Carey v. Carey, Index No. 152192/2021
| Detail | Information |
| Case name | Carey v. Carey, et al. |
| Court | Supreme Court of the State of New York, New York County |
| Index number | 152192/2021 |
| Plaintiff | Morgan Carey |
| Defendant at the end | Mariah Carey |
| Original co-defendants | Macmillan Publishing Group (publisher), Michaela Angela Davis (co-author) and Andy Cohen Books (imprint) |
| Book at issue | The Meaning of Mariah Carey (2020) |
| Lawsuit filed | March 3, 2021 |
| Damages claimed | Reported as more than $20 million |
| Earlier ruling | February 15, 2022, Justice Barbara Jaffe: most claims dismissed; two defamation claims survived |
| Latest ruling | October 19, 2026, Justice Leslie A. Stroth: remaining claims dismissed |
| Reason | Morgan did not sufficiently plead actual malice |
| Mariah Carey’s attorney | John Rosenberg |
| Morgan Carey’s attorney | Richard Altman |
| Appeal | Stated intention to appeal; no filed notice of appeal confirmed |
| Settlement | None reported |
| Public claim form | None |
What Morgan Carey Alleged Against Mariah Carey in the Memoir Lawsuit
Morgan Carey sued in March 2021, claiming that passages in the memoir were false and defamatory and had damaged his reputation. He said the book portrayed him as violent, implied he had trouble with the law and suggested he had tried to extort money from his sister. He also claimed that negotiations over a film project he was involved in were abruptly broken off after the book came out. The complaint also included a claim for intentional infliction of emotional distress.
These were Morgan’s allegations. They were not established facts, and the case never reached a trial.
Which Two Passages in The Meaning of Mariah Carey Survived Until 2026?
In February 2022, Justice Jaffe dismissed claims over seven passages and dropped the publisher defendants. She let two defamation claims go forward. They concerned language describing Morgan as a “sometimes drug dealing, been-in-the-system” brother and passages suggesting he distributed cocaine to “the beautiful people,” which the court found could be read as accusing him of a serious crime.
Jaffe said one passage about a fight between Morgan and the siblings’ father reasonably conveyed that he was abusive toward his family. She still dismissed that claim because Morgan did not show the “special damages” the law required for it, according to Reuters.
Why Justice Stroth Dismissed Morgan Carey’s Defamation Claims Against Mariah Carey
After Jaffe retired, the case was reassigned to Justice Stroth. In the October 19 ruling, Stroth wrote that Morgan had not sufficiently pleaded actual malice. According to reports of the decision, the judge found Morgan offered no proof that Mariah made the statements knowing they were false or with reckless disregard for the truth, and that his allegation of ill will toward him was not enough.
Mariah Carey’s lawyer said she is gratified that the court recognized the memoir addresses significant issues of public interest and dismissed her brother’s claims in their entirety. Morgan’s lawyer said the team disagrees with the decision and plans to appeal.
What “Actual Malice” Means in the Mariah Carey Case
In everyday speech, malice means spite. In defamation law, actual malice is narrower. It means the speaker knew the statement was false or acted with reckless disregard for whether it was true. Disliking someone, or being estranged from them, does not meet that test on its own, and neither does failing to check a story with the person it concerns.
Does the Dismissal Mean Everything in Mariah Carey’s Memoir Is True?
No. A court can dismiss a defamation claim because the plaintiff did not plead or prove the required state of mind, without deciding whether each disputed statement was true or false.
How New York’s Anti-SLAPP Law Applies to Morgan Carey’s Lawsuit
New York’s anti-SLAPP law protects speech on public issues from lawsuits that are meant to silence it. Two parts of it matter here.
New York Civil Rights Law § 76-a: The Actual Malice Requirement
Under Civil Rights Law § 76-a, in a covered action over speech on a matter of public interest, a plaintiff can recover damages only by showing, by clear and convincing evidence, that the statement was made with knowledge of its falsity or reckless disregard for the truth, when truth or falsity is material to the claim. Mariah Carey’s lawyer emphasized after the October ruling that the memoir addresses significant issues of public interest.

New York CPLR 3211(g) and Civil Rights Law § 70-a: Dismissal Motions and Legal Fees
Under CPLR 3211(g), a court must dismiss a covered claim unless the plaintiff shows a substantial basis in law for it. Civil Rights Law § 70-a separately allows a defendant in a successful anti-SLAPP motion to seek costs and attorney’s fees in certain circumstances. The reports reviewed do not say whether Mariah Carey has asked for fees.
Why the Morgan Carey Lawsuit Took More Than Five Years
| Date | Event |
| September 2020 | The Meaning of Mariah Carey is published |
| March 3, 2021 | Morgan Carey files suit in New York Supreme Court |
| February 15, 2022 | Justice Barbara Jaffe dismisses most of the case and the claims against the publisher; two defamation claims remain |
| April 12, 2024 | Justice Leslie A. Stroth issues a published decision in the case (2024 NY Slip Op 31297(U), also published as 2024 NY Slip Op 50446(U)) |
| October 19, 2026 | Stroth dismisses the remaining claims for failure to plead actual malice |
| After October 19, 2026 | Morgan’s lawyer says he will appeal |
The filing date is March 3, 2021. Some reports say May 2021, but contemporaneous coverage from March 2021 shows the suit was filed in early March.
What Does the $20 Million Figure Mean in the Morgan Carey v. Mariah Carey Lawsuit?
The $20 million is the amount Morgan said he believed his damages exceeded. It was never awarded, and the dismissal means he won no money from Mariah in this case. No settlement has been reported.
Can Morgan Carey Appeal the Dismissal of His Lawsuit Against Mariah Carey?
His lawyer has said he will appeal. In New York, an appeal from a trial-court order generally goes to the Appellate Division, First Department, for a case in New York County. A notice of appeal generally must be filed within 30 days after the opposing party serves the order with notice of its entry (CPLR 5513(a)). The reports reviewed do not say whether the order has been entered and served or whether a notice of appeal has been filed. The reports also do not say whether the dismissal is with prejudice.
Until an appellate court rules otherwise, the claims stay dismissed.
What Does the Mariah Carey Ruling Mean for Memoir Authors and the People They Write About?
The result shows how much weight actual malice carries in a case about a public-interest book. A person who disagrees with how a memoir describes them still has to show that the author knew the statements were false or recklessly disregarded the truth. Hostility or a family rift is not enough by itself.
The ruling does not give authors permission to publish knowingly false statements, and the case does not say that every similar claim will fail.
How This Compares to Other Defamation and Dismissal Cases We Have Covered
For a defamation case that went to a jury, see Megan Thee Stallion Wins Defamation Lawsuit Against Blogger Milagro Gramz—$59K Awarded After Coordinated Harassment Campaign. Mariah Carey was also involved in a different dispute, covered in Mariah Carey Lawsuit, Singer Awarded $92,000 After Judge Dismisses “Baseless” Copyright Claim. For another dismissal where the legal ground matters, read Miley Cyrus Adoption Lawsuit, Billy Ray Cyrus Wins Dismissal in Bizarre Maternity Claim.
Each case has different facts and different law, and none changes the outcome of the Carey case.
Is There a Claim Form or Public Recovery in the Morgan Carey v. Mariah Carey Lawsuit?
No. It is an individual defamation action. Readers and other people mentioned in the memoir have no claim to make and nothing to file.
Frequently Asked Questions About Morgan Carey’s Defamation Lawsuit Against Mariah Carey
Why was Morgan Carey’s lawsuit against Mariah Carey dismissed?
Justice Leslie A. Stroth ruled on October 19, 2026, that Morgan had not sufficiently pleaded actual malice, meaning that Mariah knew the challenged statements were false or recklessly disregarded the truth.
Did Morgan Carey get $20 million from Mariah Carey?
No. The $20 million was the damages he claimed. The court dismissed the remaining claims and no award or settlement has been reported.
What did Morgan Carey say The Meaning of Mariah Carey got wrong?
He challenged passages he said portrayed him as violent, as a drug dealer and as having been “in the system.” The two claims that survived until 2026 concerned the cocaine and “in the system” language.
Was the publisher, Macmillan, part of the October 2026 dismissal?
No. The publisher defendants were dismissed in February 2022. The October 2026 ruling dealt with the remaining claims against Mariah Carey.
Will Morgan Carey appeal the ruling?
His lawyer, Richard Altman, has said the team intends to. No filed appeal has been confirmed.
What is the case number for Morgan Carey v. Mariah Carey?
Index No. 152192/2021, New York County Supreme Court.
Does the ruling prove that everything in Mariah Carey’s memoir is true?
No. The court decided only that the actual malice requirement was not sufficiently pleaded.
Is there a claim form for the Mariah Carey lawsuit?
No. It is not a class action.
Sources and Legal References
- Reuters via ABS-CBN, Judge tosses most of lawsuit by Mariah Carey’s brother over singer’s memoir, February 2022 (case number and the February 15, 2022 ruling).
- New York State Courts, Carey v Carey, 2024 NY Slip Op 31297(U), April 12, 2024 (Index No. 152192/2021; Justice Leslie A. Stroth).
- TheWrap, Mariah Carey Prevails in Brother’s $20 Million Memoir Lawsuit, October 2026.
- Law Commentary, Mariah Carey Wins Five-Year Defamation Battle With Brother Over Memoir Allegations, October 19, 2026.
- The Daily Beast, Mariah Carey’s Brother’s $20 Million Lawsuit Against Her Takes Final Twist, October 2026 (statements by both lawyers).
- Variety, Mariah Carey’s Brother Sues Her for Emotional Distress Inflicted by Memoir (republished), March 2021 (the original complaint).
- New York Civil Rights Law § 76-a and § 70-a; CPLR 3211(g) and 5513, via the New York State Senate website.
- New York State Courts, eCourts, for checking the docket and any notice of appeal.
This article is for general information only and is not legal advice. AllAboutLawyer.com is a legal information website, not a law firm, and reading it does not create an attorney-client relationship. Anyone with questions about a possible defamation claim in New York should consult a licensed New York attorney.
Researched and written by Israr Ahmad, legal content researcher and founder of AllAboutLawyer.com. All facts verified against the New York State Courts’ published decisions, Reuters, TheWrap, Law Commentary and Daily Beast reporting on the October 19, 2026 ruling, and the New York statutes cited, as of October 26, 2026. Last Updated: October 26, 2026.
About the Author
Israr Ahmad is a legal content researcher with 4+ years of experience covering class action settlements and consumer rights cases. He has researched and published coverage of 2,500+ settlements using verified court records, settlement administrator filings, and government sources. Learn more about Israr.
