A New York judge has dismissed a $20 million defamation lawsuit that Morgan Carey brought against his sister, the singer Mariah Carey, over her 2020 memoir, according to a report by Bushwick Daily.
The ruling, as summarized by the outlet, turned on a single legal question: whether Morgan Carey could show that his sister acted with actual malice. The judge found that he failed to do so, and the case was thrown out.
The standard is a demanding one. In defamation cases involving public figures, plaintiffs generally must show that the writer published a false statement knowing it was false or with reckless disregard for the truth. Falling short of that threshold is often fatal to such a claim, which appears to be what happened here, based on the summary provided by Bushwick Daily.
The lawsuit targeted Mariah Carey’s 2020 memoir, a book that has drawn wide attention since its release for its account of her childhood and family life. Morgan Carey sought $20 million in damages over how he was portrayed in its pages.
The item available to Made in NYC is limited. The text provided from Bushwick Daily’s page consisted largely of the outlet’s membership terms rather than the full body of its court coverage, so details of the judge’s reasoning, the specific passages at issue, the court in which the case was heard and the date of the decision are not available to us. We have not independently reviewed the court filings, and we are not reporting any statements from either party.
What the available summary does establish is straightforward: the claim was filed in a New York court, it sought $20 million, it concerned the 2020 memoir, and the judge ruled that the plaintiff had not proved actual malice. Whether Morgan Carey intends to appeal is not stated in the material we have.
For readers who follow the intersection of celebrity and the courts, the outcome is a reminder of how high the bar is for defamation plaintiffs in New York and across the country. A memoir is, by nature, one person’s account of events, and courts have long given writers considerable room when their subjects are real people, so long as the plaintiff cannot demonstrate the kind of knowing or reckless falsehood the law requires.
Made in NYC will update this story if additional details from the court record or from the parties become available.
Frequently Asked Questions
Why was Morgan Carey’s lawsuit against Mariah Carey dismissed?
A New York judge dismissed the $20 million defamation suit after finding that Morgan Carey failed to prove his sister acted with actual malice. Under the standard for public figures, plaintiffs must show a knowing or reckless falsehood.
What did Morgan Carey sue Mariah Carey over?
Morgan Carey sued his sister Mariah Carey for defamation over her 2020 memoir, seeking $20 million in damages for how he was portrayed in the book.
What is actual malice in a defamation case?
Actual malice means the writer published a false statement knowing it was false or with reckless disregard for whether it was true. Public figure plaintiffs must meet this demanding threshold to win a defamation claim.
Is Morgan Carey appealing the dismissal of his lawsuit?
The article does not state whether Morgan Carey intends to appeal the dismissal. That information is not available in the source material.
What details of the judge’s ruling are not known?
The judge’s specific reasoning, the passages of the memoir at issue, the court name, and the decision date were not available in the source material. The article’s author also did not independently review the court filings.
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