Burrowes v. Combs

Kirk Burrowes ran the money at Bad Boy Entertainment. He was there from 1992, was general manager and then president, and was gone by 1997. Since 2003 he has sued Sean Combs, Combs's lawyer, the company, or Combs's mother five times — twice in the same week of February 2025. Every one of those suits turns on the same allegation: that Combs came into his office with a baseball bat and made him sign away a 25% stake in Bad Boy for nothing.

He has lost three of those five actions outright, and been dismissed on the merits of that central allegation zero times. Limitations, preclusion, pleading defects — that is the whole list of reasons given. Whether anything actually happened in that office has never been put to a factfinder, and after more than two decades of litigation it is no closer to being put to one than it was in 2003.

The accounts of the incident are stable at the center and loose at the edges. In the 2003 federal complaint, Burrowes was given a quarter of the company in 1993 with a matching share of profits, then forced to give it up in writing in 1996 when Combs and attorney Kenneth Meiselas threatened him with a baseball bat (Proposed Am. Compl. ¶¶ 33, 37, 44–49, as summarized in Burrowes v. Combs, 312 F. Supp. 2d 449, 450 (S.D.N.Y. 2004)). In the 2004 state complaint it becomes a surprise office visit in May 1996, ending with him handing over the share certificate and signing a release, as recited by Justice Charles E. Ramos. In the 2025 complaint against Combs, Combs storms in with the bat and in-house counsel beside him and demands the stake "or face violent repercussions" (¶¶ 38–41); the stated motive is that Combs wanted the 25% merged into his mother's 75%. In the 2025 complaint against Janice Smalls, the same scene is relocated to a specific address on West 19th Street, the certificate for twenty-five shares passes from Combs to his mother, and Meiselas is said to have been acting at her direction (¶¶ 87–89).

The date moves with the telling. The 2004 pleading and the Smalls complaint both say May 1996; the 2025 complaint against Combs says only "1996"; Combs's own motion papers put it in 1995. Nothing in the record resolves it, and — twenty-three years in — nothing has ever reached a stage where it would need to.

Both 2025 complaints were filed by attorney Tyrone A. Blackburn, who has drawn disciplinary attention in unrelated litigation: a Southern District grievance-committee referral from Judge Denise Cote in April 2024 over a pattern of filings she found apparently designed to generate media attention and pressure settlements; pointed criticism from Judge J. Paul Oetken in March 2025 in a separate case against Combs; a sanctions order exceeding $76,000 from Judge William Stickman in unrelated litigation, over AI-generated citations; a second grievance-committee referral, from Magistrate Judge Jennifer Willis, in June 2026; and a Brooklyn indictment over a May 2025 incident with a process server, dismissed May 26, 2026 for a defect in the grand jury proceeding. Those are separate matters in other litigation and do not bear on the allegations in the Burrowes actions.

Two of Burrowes's five actions are still open. The one against Combs personally centers on a single sexual-assault count running from 1992 to 2019, and appends roughly seventy paragraphs about Tupac Shakur and Christopher Wallace that support no element of that count. Combs has moved to strike those paragraphs as immaterial and scandalous; the motion is undecided. This table separates who the filings actually sue from who they only describe.

The live action against Combs is stopped on a question that has nothing to do with 1996. New York City's Gender-Motivated Violence Protection Law reaches conduct back to its 2000 enactment through a revival window that closed March 1, 2025 — one day after Burrowes filed. Combs's motion argues that revival window is preempted by the state's own Adult Survivors Act, which carries a shorter one.

On March 23, 2026 the Second Circuit declined to decide that preemption question itself, in a different case, Parker v. Alexander, and certified it to the New York Court of Appeals instead — reasoning that it is fundamentally a question of state home rule that the state's own courts should settle. On August 25, 2026, Judge Vyskocil stayed the Burrowes action on that basis, holding that preemption is a threshold issue and that the court should not risk a ruling the Court of Appeals later contradicts. The motions to dismiss and to strike the Tupac and Wallace paragraphs were both terminated administratively rather than decided — Vyskocil's order notes the striking argument can be renewed "if it remains live after the stay is lifted." The parties must file a joint status letter within three days of the Court of Appeals' decision and every 90 days until then.

The Smalls action is not affected by that stay; it proceeds on its own track, with a renewed motion to dismiss filed August 31, 2026 and, as of this writing, briefing scheduled to run through the end of September 2026.