Mariah Carey Wins Dismissal of Brother Morgan’s Defamation Lawsuit Over 2020 Memoir
Mariah Carey has won a legal victory over her older brother, Morgan Carey, after a judge dismissed his defamation lawsuit over her 2020 memoir, The Meaning of Mariah Carey. The ruling, issued on Monday, October 19, effectively ends the case at the trial court level and represents a major win for the Grammy-winning singer, who had been accused by her brother of damaging his reputation through the book’s depiction of their difficult family history.
Morgan, 66, filed suit against Mariah, 57, back in 2021. His lawsuit alleged that Mariah defamed him in the memoir by writing that he had trafficked “powdered party favors”—a phrase his legal team interpreted as a reference to cocaine—and by suggesting that he had spent time in prison. Morgan argued that those statements were false, harmful, and made without regard for the truth. He also maintained that Mariah had allowed the commercial potential of her memoir to take precedence over verifying the facts of the story she was telling.
Judge Leslie A. Stroth, however, was not persuaded by Morgan’s arguments. In a ruling handed down on Monday, the judge found that Morgan had failed to establish that Mariah acted with actual malice. Under New York law, a plaintiff in a defamation case involving public figures and matters of public concern must demonstrate that the defendant made the allegedly defamatory statement either with knowledge that it was false or with reckless disregard for the truth. That is a high legal bar, and the judge determined that Morgan’s complaint fell short of it.
“The Court finds that Plaintiff has not sufficiently pleaded actual malice on the part of Defendant,” Judge Stroth wrote. “Plaintiff has alleged that Defendant was more concerned with the ‘commercial viability’ of her memoir than verifying the truth of her statements, and that Defendant’s sources for such statements are anonymous and/or unverifiable. Notably, Plaintiff fails to provide any proof that Defendant made such statements with knowledge of their falsity or with reckless disregard for the truth.”
The ruling was first reported by Rolling Stone and Billboard, both of which obtained the judge’s decision. It dismisses Morgan’s claims in their entirety, meaning Mariah will not have to defend the contested statements before a jury, at least for now.
Mariah’s attorney, John Rosenberg, responded to the decision in a statement to Billboard. “Ms. Carey 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,” Rosenberg said.
Rosenberg also highlighted what he described as the broader significance of the ruling for authors and memoirists. “Ms. Carey believes the importance of the Court’s decision goes well beyond her own interests in this particular litigation as it confirms that authors must be afforded broad protection when they speak out on matters of public concern,” he added.
Morgan’s legal team, however, made it clear that they are not ready to accept the outcome. Attorney Richard Altman told Rolling Stone that Morgan intends to appeal the judge’s decision. “We respectfully disagree with today’s decision as being completely inconsistent with prior rulings in the case,” Altman said. “We intend to appeal it very soon.”
The lawsuit was one of several legal and personal entanglements involving the Carey family. Mariah was the youngest of three siblings shared by her parents, Alfred and Patricia Carey. Her father, Alfred, died in 2022, and her mother, Patricia, died in 2024. Mariah also had an older sister, Alison, who likewise died in 2024. At the time of Patricia and Alison’s deaths, Mariah revealed the devastating news that she had lost both relatives on the same day.
“My heart is broken that I’ve lost my mother this past weekend,” the “We Belong Together” singer said in a statement in August 2024. “Sadly, in a tragic turn of events, my sister lost her life on the same day.” Mariah continued: “I feel blessed that I was able to spend the last week with my mom before she passed. I appreciate everyone’s love and support and respect for my privacy during this impossible time.”
Alison had previously pursued her own legal action related to the memoir, according to earlier reports. The fact that both of Mariah’s siblings became involved in litigation over the book underscored the painful family history that Mariah chronicled in its pages. The Meaning of Mariah Carey, published in 2020, was written as an intimate and unflinching account of the singer’s life, from her childhood to her rise to international superstardom. The book touched on her complicated relationships with her parents and siblings, the struggles she faced growing up, and the emotional scars that stayed with her long after she became one of the most successful recording artists in the world.
For legal observers, the judge’s ruling is a reminder of how difficult it can be to win a defamation case based on statements in a memoir. Actual malice is not the same as carelessness or poor judgment. A plaintiff cannot simply show that a statement is false, or that the author made a mistake, or that the author stood to make money from the book. Instead, the plaintiff must prove that the author knowingly published a lie or acted with a blatant disregard for whether the statement was true. The judge’s reasoning in this case suggests that Morgan’s allegations, while serious, were built on inference rather than direct proof.
Morgan argued that Mariah had financial incentives to exaggerate or fabricate portions of her life story. The memoir was a commercial project, and Mariah was motivated to make it compelling. The judge acknowledged that this argument was part of Morgan’s complaint, but concluded that commercial motivation alone is not enough to establish actual malice. Similarly, the judge noted that Mariah’s reliance on anonymous or unverifiable sources was not, by itself, evidence that she acted recklessly. Without concrete proof that Mariah knew the statements were false, or that she deliberately ignored obvious signs of falsity, Morgan’s claim could not proceed.
Morgan’s attorney, however, believes that the ruling conflicts with earlier decisions in the case. His reference to “prior rulings” suggests that some of Morgan’s claims had previously survived procedural challenges and that the case had advanced through earlier stages of litigation. An appellate court may now be asked to review whether Judge Stroth applied the correct legal standard, and whether Morgan should be given another opportunity to present his case. For now, the dismissal stands.
The decision also has broader implications for authors, memoirists, and publishers. Memoirs are inherently personal and subjective. They are often based on memory, perception, and deeply felt experience rather than on objective, verifiable facts. If defamation suits could easily be brought against authors simply because family members disagreed with their accounts, the fear of litigation could chill important personal expression. Mariah’s attorney made precisely this point in his statement, emphasizing the need for broad protection for writers who speak out on matters of public concern.
The case also highlights the complex and often painful legacy of the Carey family. Mariah has spoken openly over the years about the challenges she faced growing up, the estrangements that marked her relationships, and the lasting impact those experiences had on her life and career. Her memoir was an attempt to tell that story in her own words, but it also reopened old wounds and led to public disputes with her siblings. With this latest ruling, the courts have sided with Mariah on the central legal question: whether her account of her own life was published with actual malice.
As the appeals process moves forward, the public may hear more arguments about the nature of memoirs, the limits of defamation law, and the rights of authors to tell their own stories. For now, though, Mariah Carey has achieved a decisive legal victory. Her brother’s defamation lawsuit has been dismissed in its entirety, and the singer has been given the legal protection that comes with a court finding that her words were not published with the kind of reckless disregard required to sustain a defamation claim.
