A judge has thrown out Sean “Diddy” Combs’ $100 million defamation lawsuit over the 2025 Peacock documentary The Making of a Bad Boy.
Combs sued Peacock and NBCUniversal last year, claiming the documentary “advances the false narrative” that he had a hand in the deaths of multiple people in his orbit, including The Notorious B.I.G., his children’s mother Kim Porter, record executive Andre Harrell and rapper Heavy D. But on Monday (April 20), a New York judge said nothing in the documentary rises to the level of “grossly irresponsible journalism.”
“Instead, the documentary demonstrates a carefully curated and nuanced approach which discloses interviewees’ biases and includes counterstatements to the allegedly defamatory statements,” wrote Judge Phaedra F. Perry-Bond. “The documentary provides viewers with numerous viewpoints, coupled with objective information, from which the viewer may draw their own conclusions.”
In interviews featured in The Making of a Bad Boy, musician Al B. Sure! theorized that Combs killed Porter, Harrell and Heavy D to stop all three from publicizing negative information about him. “Why is everybody dead?’ asked Al in a documentary clip. “Oh, it’s a coincidence? Get the f— out of here.”
In another portion of the documentary, Combs’ former bodyguard Gene Deal also suggested that the mogul might have had a role in Biggie’s famously unsolved 1997 murder: “The week in which Big was murdered, [Combs] was acting real anxious trying to get Big at this party,” said Deal in his interview.
Combs vehemently denies all these claims, and he alleged in his lawsuit that NBC “utterly disregarded professional standards of information gathering” in airing them. In Monday’s order, however, Judge Perry-Bond said the documentary was actually quite diligent in rebutting and contextualizing these accusations.
For example, the judge pointed out, the documentary specifically cited autopsy results showing that Porter and Heavy D died from pneumonia and heart failure, respectively, and said police do not suspect any foul play in the deaths of Porter, Heavy D or Harrell. NBC also included a statement from Porter’s children that Combs had no role in her death and noted that Combs has always denied involvement in Biggie’s murder.
Judge Perry-Bond further said NBC did its due diligence by clearly disclosing that Al B. Sure! and Deal both held grudges against Combs when they made these claims (Al dated Porter before Combs, and Deal said in the documentary that he stopped working for Combs “because me and his momma got into it”).
“Given the record conclusively establishes defendants did not act in a grossly irresponsible manner, the court will not entertain plaintiff’s second-guessing of editorial content,” wrote the judge. She dismissed the lawsuit entirely, also noting that Combs is somewhat “libel-proof” because of his federal prostitution conviction and slew of civil sexual misconduct cases: “It is inconceivable as to how the documentary created additional damage to plaintiff’s reputation, which was already tarnished.”
A lawyer for NBC, Connor Sullivan of Gibson Dunn, told Billboard, “This is an important ruling that protects filmmakers and journalists by dismissing this meritless complaint as barred by New York law and the First Amendment.”
A rep for Combs declined to comment on the decision.
Combs is currently serving a four-year prison sentence for arranging cross-country prostitution events known as “freak-offs.” He’s appealing and arguing that the sentence was unduly harsh, given that jurors acquitted him of more serious sex-trafficking and racketeering charges.
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