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New York Judge Dismisses 2015 John Doe Sexual Battery Suit Against Sean 'Diddy' Combs as Time-Barred

Non-retroactivity of New York’s 2019 extension rendered the 2015 claim untimely in both jurisdictions.

Overview

  • Justice Leslie A. Stroth granted a motion to dismiss the February 2025 lawsuit, finding the sole sexual battery claim untimely and throwing out the case against Combs and his companies.
  • The court held that CPLR §213-c’s 2019 expansion to a 20-year limitations period does not apply to pre-2019 conduct and, under CPLR 202, the claim was also untimely under California law.
  • The ruling noted no facts were pleaded to support tolling or revival under California’s AB 2777, which can reopen some older sexual assault claims through 2026.
  • Plaintiff’s attorney Tony Buzbee called the dismissal a procedural setback and said he plans to refile the case in California, where the alleged 2015 incident occurred.
  • Combs remains jailed after a July conviction on two counts of transporting individuals for prostitution, with federal sentencing set for Oct. 3, as other civil cases proceed and some have been dismissed on procedural grounds.