NEW YORK — A New York judge has dismissed a defamation lawsuit filed by Mariah Carey’s brother, Morgan Carey, over allegations in her 2020 memoir, The Meaning of Mariah Carey, according to court documents dated October 19, 2026. The ruling marks the conclusion of a five-year legal battle, with the court finding that Morgan failed to prove Mariah acted with “actual malice” — a legal standard requiring evidence that she knew her statements were false or recklessly disregarded the truth.
Timeline of the Legal Battle
In 2022, Judge Barbara Jaffe dismissed 14 of 16 claims in the original complaint and ruled that Mariah could be liable for allegations that Morgan sold cocaine in the 1980s and had been in the system.
Morgan’s legal team appealed, leading to an amended complaint in January 2026.
Legal Standards and Ruling
Judge Leslie A. Stroth, who took over the case after Jaffe’s retirement, ruled on October 19, 2026, that Morgan failed to meet the high threshold for defamation involving public figures. Under New York’s Anti-SLAPP law, plaintiffs must provide clear and convincing evidence
of actual malice. The court noted that Morgan’s allegations — including claims that Mariah’s statements about him being a drunk-ass brother
or “ex-brother” — did not satisfy this standard.
While plaintiff alleges that [Mariah] demonstrates ill will towards her brother, such statement is insufficient,
Stroth wrote. Plaintiff has not satisfied the pleading requirement for actual malice.
Reactions and Next Steps
Mariah’s attorney, John Rosenberg, stated that the ruling affirmed the importance of protecting authors’ freedom to address public concerns. 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,
he said in a statement to People.
Morgan’s lawyer, Richard Roth, indicated plans to appeal, calling the decision inconsistent with prior rulings.
Roth argued that the court had literally ignored
a 2022 ruling by Judge Jaffe that allowed some claims to proceed. However, the latest decision emphasized that the focus on actual malice — not prior procedural rulings — determined the outcome.

During the litigation, Morgan alleged that the memoir damaged his professional opportunities, including a film project he co-wrote that was reportedly canceled after the book’s publication. He also claimed the book’s portrayal of him as a physically abusive
figure led to extreme mental anguish.
Context of the Memoir and Family Dynamics
The case highlights tensions within the Carey family, with Mariah’s legal team arguing that her account of events was protected under free speech. Authors must be afforded broad protection when they speak out on matters of public concern,
Rosenberg said.
What Comes Next?
Morgan's legal team has signaled intent to challenge the ruling, but the case's dismissal highlights the difficulty of proving defamation against public figures. For now, Mariah Carey’s memoir remains unscathed, with the court’s decision emphasizing the balance between personal grievances and the right to free expression.