Mariah Carey Wins Dismissal of Brother's $20 Million Memoir Lawsuit

A New York judge has thrown out Morgan Carey's remaining defamation claims against his sister, Mariah Carey, ending — for now — a five-year fight over her bestselling 2020 memoir, The Meaning of Mariah Carey. He had sought damages he said were "believed to exceed $20 million."

Justice Leslie A. Stroth of the New York State Supreme Court ruled Monday that Morgan Carey failed to show the singer acted with "actual malice" — the legal standard requiring proof that a defendant made a false statement knowing it was false, or with reckless disregard for the truth.

"Plaintiff has not sufficiently pleaded actual malice on the part of [Mariah]," Justice Stroth wrote. "While plaintiff alleges that [Mariah] demonstrates ill will towards her brother, such statement is insufficient."

What did the memoir actually say?

Morgan Carey's lawsuit, filed on May 28, 2021, claimed the memoir damaged his "excellent and spotless reputation" in three main ways:

• It portrayed him as violent.

• It accused him of trafficking "powdered party favors" — his filing's phrase for cocaine.

It described him as having "behavioral problems" during childhood.

He argued Mariah Carey drew some of this material from their late mother and cared more about the memoir's commercial success than about verifying her claims.

Why did the claim fail?

The mechanism here is New York's anti-SLAPP law (a statute designed to stop lawsuits used to silence speech on public issues). Under that law, a plaintiff can't win just by showing bad blood. Justice Stroth found that pointing to the deterioration of the siblings' relationship doesn't amount to proof of actual malice — the missing ingredient in Morgan's case.

That distinction matters. The judge effectively treated the memoir as addressing matters of public interest, which raises the bar for defamation claims against it.

What does this change for authors?

Mariah Carey's lawyer, John Rosenberg, framed the ruling as bigger than one celebrity dispute. The singer "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," he said in a statement to Rolling Stone.

Rosenberg added that the Grammy winner "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."

For memoirists and publishers, that's the practical takeaway: New York courts will demand concrete evidence of knowing falsity, not just family friction, before a defamation suit over a tell-all can proceed.

The case isn't over

Morgan Carey's attorney, Richard Altman, told Rolling Stone an appeal is coming. "We respectfully disagree with today's decision as being completely inconsistent with prior rulings in the case," Altman said in an email. "We intend to appeal it very soon."

So the five-year litigation could stretch longer. For now, though, The Meaning of Mariah Carey stands as published — and its author has a court ruling behind her.