A Manhattan federal judge has dismissed a civil lawsuit accusing music mogul Sean “Diddy” Combs of sexual assault at a 2022 party, ruling that the claim was filed too late under New York’s statute of limitations.
U.S. District Judge Ronnie Abrams held that plaintiff Eman Barzi’s allegations fall under New York’s one-year limitations period for assault and battery claims, not the longer deadlines available under California law, where the incident allegedly occurred.
Barzi sued Combs and several of his business entities in October 2024, claiming the artist groped him during a private encounter at a promotional event. The complaint describes unwanted sexual contact that Barzi says took place after Combs invited him into an office at the party.
Barzi attempted to bring the claim under California law, which allows two years for sexual battery cases and up to ten years under certain extensions. The court ruled that New York’s “borrowing statute” requires applying the shorter statute of limitations when nonresidents sue over conduct that occurred outside the state.
New York does not recognize a standalone civil claim labeled sexual assault. Instead, courts treat such cases as battery, which carries a one-year filing deadline. Judge Abrams also rejected the plaintiff’s argument that a separate state law allowing a 20-year window for serious sex crimes should apply, finding that the allegations — described as forcible touching over clothing — do not meet the statute’s listed offenses.
“The applicable New York statute of limitations is the typical one-year period for assault and battery,” the judge wrote.
The court dismissed the claims against Combs’ businesses as well, stating the complaint relied on broad assertions that the companies knew or should have known about alleged misconduct without offering specific supporting facts.
Judge Abrams allowed Barzi an opportunity to amend his complaint, though she questioned whether he could add facts that would overcome the timing issue. Barzi’s attorney, David Fortney of The Buzbee Law Firm, said the legal team plans to refile the case in California instead, where they believe the claims remain timely.
The lawsuit is one of several legal matters facing Combs. In recent years, he has confronted multiple civil accusations of sexual misconduct. He also faces criminal consequences after a Manhattan federal jury convicted him of transporting former partners for prostitution, resulting in a 50-month prison sentence. He was acquitted of other charges tied to alleged trafficking and racketeering activity.
Counsel for Combs did not immediately respond to requests for comment.
The case is Barzi v. Combs et al., No. 1:24-cv-07973, in the U.S. District Court for the Southern District of New York.
