As Diddy Awaits Sentencing, Judge Dismisses Racketeering Claims Against His Mother
A federal judge in Los Angeles has dismissed racketeering claims against Janice Smalls Combs, the mother of Sean “Diddy” Combs, ending a high-stakes publishing royalties dispute more than two decades after it allegedly began.
In a final judgment entered on September 19, 2025, U.S. District Judge Percy Anderson ruled that plaintiff Deon “D1” Best’s civil RICO claims were barred by the statute of limitations. The dismissal was entered with prejudice, permanently closing the door on those claims. Best’s state-law claims — including fraud, conversion, unjust enrichment and conspiracy — were dismissed without prejudice, allowing them to be refiled in California state court. The judgment also ordered that Best “shall take nothing” and that Combs and her publishing companies may recover their costs.
The court, however, found the allegations untimely. In a January 30 order, Judge Anderson wrote: “It is unclear from the allegations why Plaintiff would not have had enough information prior to [October 2023] to warrant an investigation which, if reasonably diligent, would have led to the discovery of fraud.” He also noted that the complaint did not allege any “new overt act within the limitations period” that would satisfy the Ninth Circuit’s separate accrual rule for RICO claims.
With the September judgment, the federal case is over. Best may still attempt to pursue his state-law claims in state court, but the racketeering allegations against Combs are permanently closed.
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