HBO parent company Warner Bros. has argued the scandal-plagued R&B singer is “libel proof” because his reputation “cannot sink any lower.”
LOS ANGELES (CN) — A Superior Court judge indicated Thursday he is likely to throw out a defamation lawsuit filed by R&B artist Chris Brown over the HBO documentary, “Chris Brown: A History of Violence,” on First Amendment grounds.
Brown’s long and successful music career, having sold over 140 million records worldwide, has been eclipsed by his sordid legal history, which began in 2009 when he pleaded guilty to assaulting his then-girlfriend, Rihanna. In 2013, while still on probation, he punched a man in the face in Washington, D.C. and pleaded guilty to misdemeanor assault.
He has been accused of punching singer Frank Ocean, as well as his former manager, a photographer and at least one ex-girlfriend. Since 2018, he has been sued by at least three women over sexual assault claims. One of the suits was settled out of court, while the other two were dismissed by judges.
In 2024, HBO released its 84-minute documentary, taking stock of the accusations leveled at Brown. The movie featured an interview with Chantel Dasia Frank, who appeared in silhouette to mask her identity. She had filed one of the lawsuits against Brown that had been dismissed, accusing the singer of drugging and raping her aboard a yacht in 2020 at a New Year’s Eve party hosted by Sean “Diddy” Combs.
Brown sued HBO’s parent company Warner Bros. in 2025, also naming as defendants Chantel Frank and three other women interviewed in the documentary: cultural critic Scaachi Koul, TV journalist Sharon Carpenter, activist Michelle Taylor and Sergeant Cheryl Dorsey, a 20-year veteran of the Los Angeles Police Department. Dorsey says in the movie: “Chris Brown is an amazing and talented musician, but let’s call a thing a thing: I think he’s an abuser of women — consistently, unapologetically.”
“Mr. Brown has never been found guilty of any sex-related crime (rape, sexual battery, sexual assault, etc.) but this documentary states in every available fashion that he is a serial rapist and sexual abuser,” Brown wrote in his complaint, saying the movie was “full of lies and deception and violating basic journalistic principles.”
The defendants all filed anti-SLAPP motions — three in total — to dismiss the lawsuit on First Amendment grounds. The other two motions are scheduled to be heard in subsequent weeks.
“This suit is a garden-variety attempt by a celebrity plaintiff to penalize protected speech reporting on court proceedings and criminal investigations,” Warner Bros. wrote in their motion.
The company also wrote that Brown was “libel proof,” because his reputation was “irredeemably tarnished long before the documentary aired” and “cannot sink any lower.”
In his tentative ruling, Superior Court Judge Colin Leis did not address the “libel proof” argument, but he did write that Brown was a “prominent public figure,” and that the documentary, as well as the statements made in it, “arise from protected activity.” The statements Brown objected to, he wrote, were either “fair and true,” opinion or statements for which Brown had provided “no evidence of falsity.”
Evan Selik, Brown’s attorney, told Leis that a police report about Frank’s accusation “concluded no sexual battery occurred.” That meant, Selik argued, that including her interview in the documentary amounted to knowingly publishing false information.
“This isn’t accurate reporting,” Selik said. At the very least, he argued, “it’s a question of fact for the jury.”
Warner Bros. attorney Jonathan Segal pointed out that the documentary included many of the facts that cast doubt on Frank’s account.
“Reasonable minds can’t disagree that we accurately reported the facts,” Segal said.
Leis did not issue a final ruling, but gave no indication that he would change his mind from the tentative ruling.