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A federal judge in Manhattan has dismissed a civil lawsuit accusing music mogul Sean Combs of sexual assault, ruling that the claim was filed after the deadline allowed under New York law.
U.S. District Judge Ronnie Abrams found that the allegations brought by plaintiff Eman Barzi fall under New York one year statute of limitations for assault and battery. Because the lawsuit was filed beyond that period, the court said it cannot proceed in New York.
Barzi sued Combs and several of his business entities in October 2024. He alleged that Combs groped him during a 2022 promotional event, describing unwanted sexual contact after he was invited into a private office at the party.
Although the alleged incident took place in California, Barzi filed the case in New York and sought to rely on California law. That state allows two years to file sexual battery claims and in certain situations provides extensions of up to 10 years.
Judge Abrams said New York borrowing statute requires courts to apply the shorter statute of limitations when a nonresident brings a claim over conduct that occurred outside the state. In this case, that meant applying New York one year deadline.
New York does not recognize a standalone civil claim labeled sexual assault. Instead, such allegations are treated as battery, which carries a one year filing window.
“The applicable New York statute of limitations is the typical one year period for assault and battery,” Abrams wrote in her decision.
Barzi also argued that a separate New York law allowing a 20 year window for certain serious sex crimes should apply. The judge rejected that position, concluding that the conduct described in the complaint, characterized as forcible touching over clothing, does not fall within the offenses covered by that extended period.
The court dismissed the claims against Combs business entities as well. Abrams said the complaint relied on broad and conclusory assertions that the companies knew or should have known about alleged misconduct, without providing detailed supporting facts.
While dismissing the case, the judge granted Barzi an opportunity to amend the complaint. She questioned, however, whether any additional facts could overcome the statute of limitations hurdle.
Barzi attorney, David Fortney of The Buzbee Law Firm, said his team intends to pursue the matter in California instead, where they believe the claims remain timely under that state law.
The lawsuit adds to a growing list of legal troubles for Combs in recent years. He has faced multiple civil accusations of sexual misconduct. In a separate criminal case, a Manhattan federal jury convicted him of transporting former partners for prostitution. He was sentenced to 50 months in prison and acquitted of other charges tied to alleged trafficking and racketeering activity.
Attorneys for Combs did not immediately respond to requests seeking comment on the dismissal.
The case is Barzi v. Combs et al., filed in the U.S. District Court for the Southern District of New York.
