Mariah Carey wins dismissal of brother's defamation lawsuit over her memoir

US judge rules Morgan Carey failed to show singer acted with actual malice in 'The Meaning of Mariah Carey'

By LineZotpaper

Published21 October 2026

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A New York judge has dismissed the defamation lawsuit Mariah Carey's brother Morgan brought over her 2020 memoir, The Meaning of Mariah Carey, ruling he failed to prove the singer knew her account was false or recklessly disregarded the truth, the standard required in matters of public interest.

Mariah Carey has won dismissal of the defamation case her brother Morgan brought over her 2020 memoir, The Meaning of Mariah Carey, five years after he accused her of ruining his reputation.

In the book, Carey described Morgan as a "sometimes drug dealing, been-in-the-system, drunk-ass brother" and called him her "ex-brother". He sued in New York's supreme court in 2021, alleging she falsely portrayed him as a violent drug dealer with a criminal record, and that her claim he had physically abused their mother was "a false and defamatory lie". He said the memoir had "ruined" him and caused "extreme mental anguish".

In 2022, judge Barbara Jaffe threw out 14 of 16 claims and dismissed all claims against the publisher, Macmillan. She ruled Carey could still face defamation liability over claims her brother sold cocaine in the 1980s and had "been in the system", but noted Morgan had failed to demonstrate he suffered damages.

In an amended complaint filed in January, Morgan's attorneys said the production of a film he co-wrote was called off after the memoir's publication, allegedly because of a producer's "fear of angering" his sister, and claimed "in excess of $1.5m" in connection with the cancellation, plus unspecified damages for emotional distress.

Judge Leslie Stroth dismissed the complaint in documents filed on Monday, finding Morgan had not shown Carey knew what she wrote was false or recklessly disregarded the truth. His belief that Carey felt "ill will" towards him was "insufficient" proof of actual malice, she wrote.

Carey's lawyer, John Rosenberg, told People magazine that Carey "is gratified that the court recognised that her memoir addresses significant issues of public interest and dismissed her brother's defamation claims in their entirety". The decision "confirms that authors must be afforded broad protection when they speak out on matters of public concern", he said.

Richard Roth, one of Morgan's attorneys, told Variety on Tuesday that he would appeal again.

Morgan's sister Alison also sued in 2021, seeking $1.2m over what she called "cruel and outrageous allegations" in the memoir, including claims that Carey was burned with hot tea and offered drugs as a child. Alison did not pursue the lawsuit and died in 2024, aged 63.

Analysis

Why This Matters

The ruling applies the actual malice standard to memoirs dealing with matters of public interest, a principle Carey's lawyer argues extends well beyond this case
It closes a five-year legal battle for Carey, although her brother's attorney says an appeal is planned
The decision, if it stands, strengthens legal protection for authors writing about difficult personal and family history

Background

The case turned on a long-established principle of US libel law: public figures who sue for defamation must prove the publisher knew the statement was false or acted with reckless disregard for the truth, a high bar intended to protect speech on matters of public concern. Carey's memoir recounted her difficult upbringing and her claims about her family members. Morgan consistently denied the book's portrayal of him, saying it wrongly branded him as violent and dishonest and cost him work.

Key Perspectives

Mariah Carey and her legal team: The memoir addresses significant issues of public interest and the court confirmed that, with her lawyer arguing authors need broad protection when speaking on matters of public concern.

Morgan Carey and his attorneys: He maintains the book falsely portrayed him as a violent drug dealer with a criminal record and harmed his career and emotional wellbeing, and his lawyer says he will appeal.

Critics and skeptics: The actual malice standard is deliberately hard for plaintiffs to meet, and Morgan's case also struggled to show damages. Whether an appeals court accepts the public interest framing, and whether Morgan can produce evidence Carey knew her claims were untrue, remain open questions.

What to Watch

Whether Morgan Carey follows through on his attorney's pledge to appeal the dismissal
Any further developments in the family litigation, including the claims Alison Carey did not pursue before her death in 2024
How courts weigh public interest defences in future defamation suits over memoirs and biographies

Sources

Mariah Carey wins dismissal of brother’s defamation lawsuit over her memoir · World news | The Guardian

Checked

12 claims in this story checked against 1 source: 12 supported.

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SupportedMariah Carey won dismissal of her brother’s defamation lawsuit over her memoir.World news | The Guardian: “A judge has dismissed a lawsuit from Mariah Carey’s brother, five years after he accused her of defaming him in her 2020 memoir, The Meaning of Mariah Carey.”
SupportedMorgan Carey failed to show that Mariah Carey knew her account was false or recklessly disregarded the truth, the standard for matters of public interest.World news | The Guardian: “finding he had failed to show that his sister knew that what she was writing was false or that she had recklessly disregarded the truth, meaning his lawsuit fell short of the bar needed in matters of public interest.”
SupportedCarey described Morgan as a “sometimes drug dealing, been-in-the-system, drunk-ass brother”.World news | The Guardian: “In the memoir, Carey described Morgan as a “sometimes drug dealing, been-in-the-system, drunk-ass brother” and called him her “ex-brother”.”
SupportedCarey called Morgan her “ex-brother”.World news | The Guardian: “In the memoir, Carey described Morgan as a “sometimes drug dealing, been-in-the-system, drunk-ass brother” and called him her “ex-brother”.”
SupportedMorgan alleged Carey’s claim that he physically abused their mother was “a false and defamatory lie”.World news | The Guardian: “Morgan first sued his sister in New York’s supreme court in 2021, alleging that she had falsely portrayed him as a violent drug dealer who had been to prison, and that her claim that he had physically abused their mother was “a false and defamatory lie”.”
SupportedIn 2022, Judge Barbara Jaffe dismissed 14 of Morgan’s 16 claims and all claims against publisher Macmillan.World news | The Guardian: “In 2022, judge Barbara Jaffe threw out 14 of 16 claims in Morgan’s original complaint, and dismissed all claims against the book’s publisher, Macmillan.”
SupportedJudge Jaffe ruled Carey could be liable over claims that Morgan sold cocaine in the 1980s and had “been in the system”.World news | The Guardian: “Jaffe ruled that Carey could be liable for defamation for alleging that her brother sold cocaine in the 1980s and that he had “been in the system”.”
SupportedMorgan sought more than $1.5 million over the cancellation of a film he co-wrote, plus unspecified emotional-distress damages.World news | The Guardian: “He sued for “in excess of $1.5m” in relation to the film’s cancellation, as well as additional unspecified damages for emotional distress.”
SupportedCarey’s lawyer John Rosenberg said she was gratified by the ruling and that it dismissed her brother’s claims in their entirety.World news | The Guardian: “Carey’s lawyer, John Rosenberg, told People magazine that she “is gratified that the court recognised that her memoir addresses significant issues of public interest and dismissed her brother’s defamation claims in their entirety”.”
SupportedRosenberg said the decision confirms authors should have broad protection when speaking on matters of public concern.World news | The Guardian: “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 said.”
SupportedMorgan’s attorney Richard Roth told Variety on Tuesday that Morgan would appeal again.World news | The Guardian: “Richard Roth, one of Morgan’s attorneys, told Variety on Tuesday that he would appeal again.”
SupportedAlison Carey filed a $1.2 million suit in 2021 and did not pursue it; she died in 2024, aged 63.World news | The Guardian: “In 2021, the Careys’ sister Alison also filed a $1.2m defamation suit against Mariah over “cruel and outrageous allegations” in the memoir, including the singer’s claims that Alison left her with third-degree burns after she threw a cup of hot tea on her back, offered her drugs, and sedated her with Valium when she was 12. […] However, she did not pursue the lawsuit and died in 2024, aged 63.”