A New York U.S. District Court dismissed a sexual assault suit filed against Sean “Diddy” Combs after the plaintiff Jane Doe dropped the suit. The dismissal follows a ruling from Judge Lewis Liman that the plaintiff was not authorized to proceed anonymously and was required to resubmit the complaint in her actual name. The plaintiff had not resubmitted before the court-ordered deadline date of March 20, 2025.
The October 2024 suit charged Combs with raping the plaintiff at a 1995 bash in New York where a Biggie Smalls music video was being made. The plaintiff, whose attorney was Texas-based lawyer Tony Buzbee, sought anonymity because he was afraid he would be subject to scrutiny in public. But Judge Liman ruled that the seriousness of the charge was not sufficient to permit anonymity because U.S. courts generally require plaintiffs to appear unless they can prove a real threat of harm.
Judge Liman’s dismissal of the case follows legal precedents requiring plaintiffs in civil cases to disclose their identities unless they can establish extraordinary harm or risk. The ruling follows a series of similar cases where courts have turned down anonymity and upheld the legal principle that the defendant has a right to know his accuser.
The lawyer to Combs praised the verdict and condemned the recent spate of filing anonymous cases against the rap mogul. “For months we have seen case after case filed anonymously and driven forward by lawyers with a priority on publicity over merit in the law. The remaining cases, including the one dismissed today, will not be sustained in a court of law,” Combs’ attorneys stated.
Attorney Tony Buzbee discussed the challenges his client and sexual assault survivors in general have to go through.
“The cases are tough cases and they’re often re-traumatizing to the person who brings them. Each case has merit individually. The woman didn’t want to proceed and subject herself to the media circus and the threat that she perceived,” said Buzbee.
On the contrary, Combs’ attorneys said that this was not the first case they had filed on behalf of their client to be dismissed. “This is now the second case filed by these attorneys that has been dismissed in its entirety,” they said.
This dismissal comes in the wake of a bigger trend in Combs’ cases, several of which have been subject to legal challenges over anonymity and the retrospective application of laws. Combs’ attorneys successfully had charges dismissed in another sexual assault case in April 2024 on the basis that laws such as the The New York Services for Victims of Human Trafficking Law (2007) and the New York State Revenge Porn Law (2019) were not retrospectively applied to offenses committed in the 1990s.
In another case, a federal judge dismissed a civil suit filed by a 39-year-old man who accused Combs of sexual assault at a 2022 New York house party. The suit was dismissed because the plaintiff, identified only as “John Doe,” had filed the suit anonymously without court permission.
Also, Combs has multiple suits pending against him, including one filed by music producer Rodney “Lil Rod” Jones, who accused him of sexual assault, harassment, and drugging. Combs moved to dismiss Jones’ suit in August 2024 on grounds that the claims were false attempts to receive media attention and get a settlement.
The case has received extensive media attention because celebrity cases have always garnered huge public interest. The anonymity issue in such cases has been controversial with arguments from both sides that publication of plaintiffs’ identities will discourage victims from filing cases and others citing the necessity to have transparency to ensure fairness in legal proceedings.
While Combs is mired in several legal cases, including a federal sex trafficking charge, the resolutions in those cases have the potential to establish important precedents in future cases concerning high-profile individuals.
Judge Liman’s decision tracks precedent in similar cases. U.S. District Court Judge Mary Kay Vyskocil in October 2024 denied anonymity to a female who was bringing a suit against Combs in connection with a 2004 rape, stating the defendant had a right to question the credibility of the plaintiff.
Another judge in December allowed a client of Buzbee to appear in a suit against Combs and Jay-Z anonymously because the claims were so delicate. With Combs’ lawyers fighting to unmask accusers in many cases, only time will tell what will come of future cases. A couple of plaintiffs have come forward and made themselves publicly known to bring cases forward, including Candice McCrary and Anna Kane. Others have had cases dismissed because they were not able to hurdle anonymity-based barriers.
