LOS ANGELES — A state appeals panel has ruled a judge incorrectly allowed two women to continue their lawsuit accusing hip-hop label Top Dawg Entertainment of improperly disclosing their identities in a press release responding to the women's own statement that they released on the eve of the Grammys promoting their legal action against Top Dawg.
The women, Linda Luna and Ayah Altayri, had filed a December 2024 lawsuit against Top Dawg, along with Top Dawg executives Brandon Tiffith and Anthony Tiffith Jr. and employee David Harrell. In that lawsuit, they listed their names only as Jane Doe and Jane Roe. According to court records, the women didn’t ask the court to be allowed to proceed under pseudonyms, either upon filing the lawsuit or serving Top Dawg notice the next month.
In the underlying complaint, Luna, as Doe, alleged sexual battery and harassment at the hands of the Tiffiths and claimed she was unpaid for providing services from 2019 through 2014. Altayri, as Roe, alleged Harrell sexually assaulted and harassed her while she lived in a home Top Dawg owned to provide moral support to a new artist.
The women, through their attorneys from Arns Davis Law and Brandon Banks Law, issued a press release two days before the 2025 Grammys summarizing the complaint. When the company responded the next day, it named the women and said their pursuit of $48 million relied on “fabricated claims,” noted they never worked for the company and claimed to have “text messages and communications that totally refute” the complaint.
The women amended their complaint in February 2025 to add a claim of doxing against Top Dawg. That April, the company responded with an anti-strategic lawsuit against public participation motion to strike the doxing claim. The women responded by conceding the claim rose from protected activity but still contended they could prove a chance to win at trial.
In June 2025, Los Angeles County Superior Court Judge Michael Whitaker denied that motion, ruling the Top Dawg press release wasn’t protected by the state’s anti-SLAPP law or any relevant privileges because naming the women wasn’t necessary to advance the company’s narrative. Although neither side had cited it, Whitaker relied on a court rule to find Top Dawg’s lawyers should’ve known that naming the women had significant potential to prejudice any court proceedings.
The women challenged that ruling before the California Second District Appellate Court. Justice Anne Richardson wrote the panel’s opinion, filed Oct. 8; Justices Victoria Chavez and Stephen Goorvitch concurred.
Before assessing the appeal, the panel detailed the proper steps for proceeding in civil court under a pseudonym, as maintaining anonymity isn’t an absolute right. After the initial filing, a plaintiff has to request an order granting permission to proceed anonymously, and a judge must consider the interest that overcomes the right of public access to court records, the potential for that interest to be prejudiced absent the order, whether the use of “a pseudonym is narrowly tailored to serve the overriding interest” and if there’s a less restrictive way to reach the same goal.
Beyond that, Richardson wrote, the state’s anti-SLAPP law protected Top Dawg’s press release, specifically falling under a clause clarifying the statute protects statements “made in connection with an issue under consideration or review by a … judicial body” and another regarding actions “in furtherance of the exercise of the constitutional right of petition or the constitutional right of free speech in connection with a public issue or an issue of public interest.”
A defendant’s statement about a lawsuit is generally protected, and allegations of sexual misconduct against prominent music industry executives is, Richardson wrote, “an issue of public interest.” The panel also reiterated that to the extent Judge Whitaker ruled the naming of the women removed anti-SLAPP protections, there was no pending motion for anonymity and therefore no violation of a court order or rule.
“We are, of course, sensitive to the nature of plaintiffs’ allegations, and they may have had a strong argument to remain anonymous,” Richardson wrote. “But it was incumbent on plaintiffs to present their request to the trial court as soon as possible. Absent filing such a motion or a statutory basis, they simply had no ‘right’ to remain anonymous while suing in court.”
During the trial the women conceded the press release was protected. They changed course on appeal, arguing the root of the doxing claim was “the electronic distribution of personally identifying information, not the exercise of free speech or petitioning rights.”
The panel disagreed, saying judges should only determine what the panel already had: Whether protected conduct is at the root of the claim. It also said the women didn’t show the likelihood of prevailing because fair report privilege also protects Top Dawg’s disclosure of their names. Richardson explained lawyers are expressly allowed to make public “identity of the persons involved” in litigation and there was no court order preventing them from doing so regarding this matter.
That their names weren’t yet part of the judicial record is immaterial, the panel said, as Top Dawg’s statement wasn’t inaccurate with respect to the identities. Although the full release included assertions favorable to Top Dawg, the women were only challenging that portion of release that included their names.
“Because that statement is unquestionably accurate, the privilege applies,” Richardson wrote.
The panel reversed Judge Whitaker’s ruling and remanded the complaint with instructions to grant the ani-SLAPP motion and strike the doxing claim. Top Dawg is entitled to compensation for its costs in defending the appeal, the justices said.
Top Dawg is represented by attorneys from the firms of Horvitz & Levy, Lavely & Singer and Singer Weinstein Wolf & Jonelis.
