LOS ANGELES — The California Court of Appeal on Thursday denied Shawn Carter’s petition for rehearing in his extortion and defamation suit against Tony Buzbee, three weeks after affirming the case’s dismissal and one week after Carter told the court that Buzbee’s former client had recanted under oath, Bloomberg Law reported. The declaration drew immediate suspicion. In court papers, Buzbee’s side called it “bought-and-paid-for,” and the questions since have been whether Jane Doe was paid, pressured or threatened into signing it.
The order modifies the panel’s Sept. 9 opinion without changing its judgment. It adds one sentence: nothing in the opinion prevents the trial court from opening new discovery. That is the whole of what Carter got for a 12-page declaration, a dismissed defendant and a petition calling the declaration “explosive new evidence” that should let his “meritorious claims to proceed.”
The case has been dogged by controversy from the start. Jane Doe alleged in her complaint that she was told Carter was threatening to kill her unless she dropped the suit. Four days before the anti-SLAPP hearing, investigators working “indirectly” for Carter showed up at her home in Alabama and secretly recorded her, a visit the trial judge excluded and the appeals court called out by name. Her dismissal came only after Carter promised that neither he nor his agents would contact her again.
Jay-Z Loses Again: Appeals Court Reads Jane Doe’s Recantation and Says No
Carter’s petition, filed Sept. 24, argued that Jane Doe’s new sworn statement “proves that discovery would yield evidence supporting Carter’s claims” and that “fairness and due process require this court to grant rehearing.” The panel, in an opinion by Associate Justice Anne Richardson, had held that Buzbee’s demand letters were protected pre-litigation communications, that “the record contains no evidence Buzbee accused Carter of raping Jane Doe while knowing those statements to be false or with reckless disregard as to whether they were true,” and that “Buzbee’s and Jane Doe’s declarations indicated litigation was genuinely contemplated in good faith.” Thursday’s order leaves every word of that in place.
Read the added sentence for what it is. The appellate court did not say the recantation changes anything. It said the trial court may decide whether it does. The trial court is Los Angeles Superior Court Judge Mark H. Epstein, who dismissed the case under the anti-SLAPP statute in June 2025 and excluded the secretly recorded interview Carter’s investigators made on Doe’s porch. Carter now has to go back to the judge who threw him out and ask for discovery on the strength of a declaration from a witness his own complaint calls unreliable.
Buzbee’s reaction to the September ruling still stands as his reaction to this one. “Sending a basic demand letter prior to filing suit is not and will never be ‘extortion,'” he said then. “I look forward to recovering my every penny of my fees and expenses.” A prevailing anti-SLAPP defendant is entitled to them. The denial of rehearing starts that clock. Carter’s remaining move in California is a petition for review to the state Supreme Court, which takes a small fraction of the cases it is asked to hear.
Meanwhile in New York: “Procured by fraud,” and “Bought-and-paid-for Declaration”
The declaration that failed in California has done its work in Manhattan. On Sept. 25, Judge Dale E. Ho approved Carter’s dismissal of Doe from his federal malicious-prosecution suit, denied her motion to dismiss as moot and terminated her as a party. The same day he granted Carter’s request for a 33-page brief against the remaining defendants, the one Buzbee’s lawyers had called “procured by fraud” because the dismissal was already “in the works” when Carter asked for their consent. We reported both letters on Monday.
Carter filed that brief Tuesday, along with an opposition to Buzbee’s motion to strike the “bought-and-paid-for Declaration.” Buzbee’s strike motion attached three exhibits: a declaration from Buzbee and the two declarations Doe signed in November and December 2024 swearing her allegations were true. Doe’s own lawyer, J. Blair Newman Jr., wrote to the judge Monday. None of those filings is public yet on the electronic docket. Buzbee’s firm also added a lawyer, Matthew Tharp, on Tuesday.
So the two courts now disagree about what the declaration is worth. In New York it has already removed a defendant and reshaped the briefing. In California it was not enough to reopen anything, only to leave a door open.
Shawn Carter’s Legal Circus
Carter has now lost in Los Angeles Superior Court, lost on appeal, and lost on rehearing. His Texas suits against Buzbee were dismissed for lack of jurisdiction. His Alabama suit was transferred to New York, where two motions to dismiss are pending. We’ve tracked each ruling and, on Tuesday, the petition that failed Thursday.
Buzbee is not without problems of his own. A federal judge in Galveston on Wednesday refused to dismiss a $25 million defamation suit against him by Marcy Croft, a Mississippi lawyer who worked for Roc Nation and whom Buzbee accused on social media of illegally soliciting his former clients to sue him. That is the same episode we covered in December 2024, now with Buzbee as the defendant.
And Jane Doe, who has now sworn both that Carter raped her and that she never met him, is out of the New York case, unmentioned in the California order, and the only person in this litigation who has nothing left to lose. The appeals court was asked to treat her latest statement as the truth. It declined to treat it as anything.
Sources: Carter v. The Buzbee Law Firm, No. B347898 (Cal. Ct. App., 2d Dist.), opinion of Sept. 9, 2026, and order modifying opinion and denying rehearing, Oct. 1, 2026; Bloomberg Law (Oct. 1, 2026); Rolling Stone (Sept. 11 and 28, 2026); Carter v. Buzbee, No. 1:26-cv-02775-DEH (S.D.N.Y.), Dkts. 170 through 180; Croft v. Buzbee (S.D. Tex., Galveston), as reported by Digital Music News (Oct. 1, 2026); Paul Smith’s reporting at Shockya. This is an opinion article.
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