A judge on Monday dismissed a lawsuit from Mariah Carey‘s brother, in which he claimed he was defamed by the superstar’s 2020 memoir, “The Meaning of Mariah Carey.”
Morgan Carey, who is 10 years older than his sister, sued in 2021, alleging that the memoir falsely portrayed him as a violent drug dealer who had “been in the system.” His suit stated that he was not violent and had no criminal record.
Judge Leslie Stroth threw out the complaint, finding that Morgan Carey had failed to show that his sister either knew what she was writing was false or recklessly disregarded the truth. The judge found that the suit therefore fell short of the high bar needed for a defamation action on matters of public interest.
A previous judge, Barbara Jaffe, threw out 14 of 16 claims in the original complaint in 2022, and dismissed all claims against the book’s publisher. However, Jaffe ruled that Mariah Carey could be liable for statements alleging that her brother distributed cocaine in the 1980s and that he had “been in the system.”
She also found that other statements — alleging that he was abusive and that he had accepted money to murder someone — could be defamatory, but that Morgan Carey had failed to properly allege that he suffered damages.
His attorneys appealed that ruling, arguing that the trial court had failed to take the full context into account, but the decision was was upheld.
Morgan Carey’s attorney, Richard Roth, said via email that he would appeal again.
“In rendering its decision, the Court literally ignored the prior decision from Justice Jaffe, that specifically held the statements were sufficient to defeat a motion to dismiss, which decision was affirmed by the First Department,” Roth said. “So, we will go up to the First Department on appeal.”
The Careys’ sister, Alison, filed a separate defamation suit over the memoir, saying it falsely portrayed her as having thrown boiling tea on Mariah Carey and as having “tried to pimp her out.” That suit was never pursued, and Alison Carey died in 2024.
Morgan Carey alleged that he was “ruined” by his sister’s memoir — which described him as her “ex-brother” — and said he had since been denied opportunities and was unable to find steady work. He also claimed that his sister had failed to fact-check passages with him before publication.
But Mariah Carey’s lawyers argued, successfully, that such an omission does not constitute “actual malice.” After five years of litigation, her lawyers argued, Morgan Carey had failed to offer more than “plaintiff’s belief that Ms. Carey acted out of some sort of ‘spite or ill will,'” which, they argued, falls well short of the legal definition of malice.