Chris Brown’s Lawsuit Against ‘History of Violence’ Accuser Survives

A judge has declined to throw out Chris Brown’s defamation claims against a woman who stated in a 2024 documentary that the R&B singer raped her on a yacht owned by Sean “Diddy” Combs.

Brown brought a $500 million libel suit last year over the documentary Chris Brown: A History of Violence, which chronicled various domestic and sexual abuse allegations against the star. A Los Angeles judge threw out claims against the film’s producers at Investigation Discovery in January after determining that they complied with journalistic standards and presented a balanced narrative.

The same judge has since declined, however, to likewise toss claims against documentary interview subject Chantel Daisia Frank. Frank alleged in the documentary that Brown raped her on a yacht docked outside Diddy’s Miami home in 2020. Brown fervently denies the claims as fabricated.

Frank’s lawyers sought dismissal under California’s anti-SLAPP statute, which gatekeeps court access for legal claims that threaten First Amendment-protected free speech. Defamation litigants must demonstrate that their claims have “minimal merit” to get over the anti-SLAPP hurdle — and Judge Colin Leis said Brown has met this standard.

The judge’s Feb. 20 order pointed to the fact that the Miami Dade Police Department looked into Frank’s rape claims and found them not to be credible due, among other reasons, to the fact that she withheld relevant text messages from investigators. Without reaching any factual determination, Judge Leis said this presents a valid question that deserves to go to trial.  

“The court cannot dismiss that a jury might believe plaintiff’s denials over Frank’s accusation that plaintiff forced non-consensual sex upon Frank — a factual question of credibility properly resolved by a jury,” wrote the judge. “Accordingly, plaintiff has established some minimal merit to his defamation cause of action sufficient for the lawsuit to proceed to its next stage.”

Judge Leis also rejected Frank’s argument that Brown is “libel proof” because of a public track record of violence, including his notorious assault of Rihanna in 2008. This does not mean Brown is incapable of being defamed, the judge said, because Brown’s “‘long and widely publicized history of violent behavior’ does not include a history of rape allegations.”

Reps for Brown and Frank did not immediately return requests for comment on the decision on Thursday (Feb. 26). The case will now move forward into evidence discovery, followed by a possible trial unless a settlement is reached.