Mariah Carey Wins Dismissal of Brother Morgan's Defamation Suit Over Memoir

A New York judge on Monday dismissed Morgan Carey's defamation suit against his sister, Mariah Carey, over her 2020 memoir, "The Meaning of Mariah Carey." Judge Leslie Stroth ruled that Morgan Carey, who is 10 years older than the singer, had failed to show that Mariah Carey either knew her statements were false or recklessly disregarded the truth.

That failure, the judge found, put the suit below the high bar set for defamation claims on matters of public interest.

Morgan Carey sued in 2021. He alleged the memoir falsely portrayed him as a violent drug dealer who had "been in the system," and stated that he was not violent and had no criminal record. He claimed he was "ruined" by the book — which described him as her "ex-brother" — and said he had since been denied opportunities and could not find steady work. He also argued his sister should have fact-checked passages with him before publication.

Why did the case fail?

The mechanism here is "actual malice" (the legal standard requiring proof that a writer knew a statement was false or recklessly disregarded the truth). Mariah Carey's lawyers argued successfully that skipping a fact-check with her brother doesn't meet that standard.

After five years of litigation, her lawyers wrote, Morgan Carey had offered nothing beyond "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.

The ruling didn't come out of nowhere. 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. Jaffe did allow the case to continue on statements alleging Morgan Carey distributed cocaine in the 1980s and had "been in the system." She also found that statements alleging he was abusive and had accepted money to murder someone could be defamatory, but that Morgan Carey had failed to properly allege damages. His attorneys appealed, arguing the trial court ignored full context; the decision was upheld.

What happens now?

Morgan Carey's attorney, Richard Roth, said 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 via email. "So, we will go up to the First Department on appeal."

The memoir has drawn one other family challenge. The Careys' sister, Alison, filed a separate defamation suit claiming the book 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.

What does this change for Mariah Carey? Not much publicly — the memoir stays on shelves unamended — but Monday's ruling leaves her brother with a single option: another trip to the First Department.