A federal judge on Sept. 19 dismissed a $33 million racketeering lawsuit filed against Janice Smalls Combs, mother of Sean “Diddy” Combs. U.S. District Judge Percy Anderson in the Central District of California granted the motion to dismiss, ruling in her favor.
Claims Dismissed With Prejudice
Deon Best, also known as D1, sued Combs earlier this year, alleging she manipulated her influence to strip him of publishing rights, royalties and intellectual property. He cited a song titled “Come With Me” from the 1998 Godzilla soundtrack, alleging Combs “hijacked artist publishing” that he claimed to own.
In his order, Judge Anderson dismissed Best’s federal RICO claims with prejudice, meaning they cannot be refiled in federal court. The accompanying state-law claims were dismissed without prejudice, leaving some room for them to be filed in state court.
The court further held that Best “shall take nothing” from the lawsuit, and it awarded Combs and her affiliated publishing companies the right to recover legal costs.
Anderson cited two principal reasons for dismissal. First, Best’s claims were time-barred under a four-year statute of limitations. Second, the court found the allegations lacked sufficient factual specificity about how and when the alleged fraud occurred.
While the door remains open for Best to pursue related claims in state court, legal observers consider that possibility unlikely. Neither Combs nor her legal team has issued a public statement yet.
This legal setback for Best comes amid a flurry of litigation involving Diddy and his business empire. In some suits, critics have raised allegations of fraud, publishing disputes, or sexual misconduct.
Combs’s legal team framed the dismissal as a vindication of high pleading standards required in federal racketeering cases. “The dismissal underscores the steep burden on plaintiffs to plead detailed facts, not broad allegations,” one insider said.
For now, Janice Combs emerges from the matter with the federal RICO threat removed. Meanwhile, her son’s ongoing legal challenges remain in the spotlight.