I am Los Angeles wrongful death attorney Michael Ehline. I grew up surfing in Orange County and listening to NWA, Dr. Dre’s Chronic, Snoop, punk rock, etc. I had a Jeep with 12-inch Rockford-Fosgate Woofers and a few thousand watts of amps. The girls at Brookes College loved me, and I even saw Snoop and Nate Dog at the local Bally’s Health Club in Long Beach. So, I have always stayed connected to anything to do with Death Row, Snoop, etc. The murder investigation of rapper Tupac Shakur has finally yielded a significant development, implicating record producer P Diddy, founder of Murder, Inc. Records.
The 25-year-old “Tupac” passed away September 13, 1996, in a Las Vegas emergency room six days after receiving fatal shots from multiple assailants. His shooting murder seems like it may be close to solved. In this unsolved case, the recent arrest of former Crips Gang Member Duane “Keffe D” Davis carries both civil and criminal implications.
Purpose of this Article?
I wrote this comprehensive article because I saw it as a helpful way to explain multiple jurisdictional and statute of limitations issues Tupac’s survivors will likely face. For example, can they pursue a wrongful death action against implicated shot caller Diddy, aka Sean “Puffy” Combs, for Tupac’s Murder? As a lawyer and fan of Biggy and Tupac music, I figured I could write something way better than Chat Gpt or a journalist could spin on legal ramifications for Pac’s surviving family.
How Was This Content Made?
I created this content using police interview transcripts from Nevada, Los Angeles, and New York, legal practice guides, news articles, published witness statements, and suspect interviews. I then integrated the facts with my advanced knowledge of wrongful death litigation. I also used general core legal principles I learned from world-class criminal death attorneys like attorney Michael J. Piuze and Gary Dordick, Esq.
I have almost two decades working exclusively on catastrophic injury claims in Los Angeles County, CA, which was very useful in helping me diagnose the facts and related wrongful death lawsuit issues related to Tupac’s 1996 shooting murder in Las Vegas, Nevada. Although I am licensed to practice wrongful death law in California and Texas, this comprehensive guide is designed to cover general principles, as a law school or bar exam might cover.
Conspirators Met in Los Angeles, New York, and Las Vegas?
Although any potential wrongful death case will likely be prosecuted civilly in the State of Nevada, the case reverberates across many jurisdictions back to California and other states. The locations and alleged events leading to Pac’s Murder occurred in many jurisdictions. Ultimately, I will share some secrets you must know to obtain maximum compensation in a CA wrongful death lawsuit.
Differences Between Wrongful Death and Murder?
The main difference between wrongful death and a murder crime lies in their legal definitions and implications:
Wrongful Death Lawsuit (Civil Action)
Wrongful death is a civil legal term used to describe a death due to someone’s negligence or criminal act. It typically involves a civil lawsuit filed by the surviving family members or beneficiaries of the deceased against the responsible party. A wrongful death lawsuit is filed to obtain compensation on behalf of survivors for the loss of their loved one after a reckless or negligent killing. The object is to cover damages, including lost income and emotional suffering. A survival action, discussed here, is a bit different.
Murder Crime (Criminal Action)
Murder is a criminal offense surrounding the unjustified killing of one person by another. A murder can be a negligence homicide, or in the First Degree, with malice aforethought.
- First-Degree Murder: Usually accompanied by premeditation and malice aforethought. (Did the killer have the intent to kill and plan it?
- Second-Degree Murder: No premeditation is required, but it still requires the intent to kill or an action that demonstrates a reckless disregard for human life.
- Voluntary Manslaughter: Voluntary manslaughter is an intentional killing without premeditation or malice aforethought, often occurring in the heat of the moment or sudden quarrel.
- Involuntary Manslaughter: This crime happens when a person unintentionally causes the death of another via negligence, recklessness, or an unlawful act not rising to a felony.
- Negligent Homicide is an unintentional killing resulting from criminal negligence or recklessness.
The state or government individuals prosecute murder cases; The defendants are subject to criminal law and criminal court proceedings to determine their guilt or innocence. If found guilty, courts impose criminal penalties, including imprisonment, fines, restitution to survivors, and sometimes, the death penalty. The object is to punish the offender for their criminal act.
Wrongful death is a civil legal concept. There are also potential survival actions discussed in the video here. In both cases, the goal is not to punish (but in egregious cases, the court can award punitive damages to the lawful survivors entitled to sue. Not just anyone can sue; only survivors of someone who died due to another person’s negligence or wrongful actions are legal plaintiffs.
The plaintiffs in a civil action have some leeway to sue and may not be required to sue in a Las Vegas court. But generally, a claim should be filed in the state where the incident occurred. However, some exceptions exist where you can sue in another state. Here are some rules about jurisdiction and venue when suing for wrongful death. In summary, unlawful death actions aim to provide survivors with total and fair compensation, whereas a murder rap seeks to punish the offender for their criminal activities.
Here, we know from a prior case filed in 1997 by Tupac’s mother, Afeni Shakur, against Orlando Anderson on September 12, 1997, for this wrongful death. (discussed in the timeline below.) However, any entitled heirs and personal representatives can file a wrongful death lawsuit or join such a claim. (Watch the video here to learn about parties entitled to sue for wrongful death.) Near the end, we will get into liability, damages, and potential statute of limitations problems. So, let’s get into the new revelation about who killed Tupac and its implications civilly and criminally for Diddy.
The Facts About Shakur’s Murder
A Nevada grand jury indicted Duane “Keffe D” Davis with Murder using a deadly weapon in killing rapper Tupac Shakur, marking the first arrest in the 27-year-old case. Davis was a ‘”leader and ‘shot caller‘ for the South Side Compton Crips gang.”‘ The investigation began on September 7, 1996. While there has been progress, Sheriff Kevin McHahill of the Las Vegas Metropolitan Police Department noted that it is still ongoing and has involved decades of effort by the homicide team. Here’s a summary of the investigation, from Shakur’s fatal drive-by shooting to Davis’ recent arrest.
November 1994: Tupac Shot and Robbed at a New York Hotel
In November 1994, two years before his tragic death, Tupac Shakur was a robbery victim inside a midtown Manhattan hotel. Shakur sustained multiple gunshot wounds and was robbed of $40,000. The wounded rapper publicly accused fellow rapper The Notorious BIG of this hit. Sean “Diddy” Combs and Biggie vehemently denied advanced knowledge of the hit
Henchman Admits Hit to Kill Shakur
In 2011, Dexter Isaac, who was serving a life sentence in a New York prison for an unrelated crime, came forward with the claim that music executive James “Henchman” Rosemond had paid him to commit a robbery against Tupac Shakur and that he had shot the rapper during that robbery. Henchman ultimately admitted his involvement here.
Isaac is still serving a life sentence for an unrelated robbery and killing. It does appear, however, that there is a connection to Puffy, sex with minor males, and the “Henchman” discussed here. Either way, Pac thought he was targeted by Biggie and, by extension, his record label.
1996 – Pac Claims Revenge Sex With Biggie’s Wife
Allegedly, the still vengeful and enraged Pac had scandalous sex with Biggie’s woman, Faith Evans, when she went to Pac’s abode after recording “Wonda Why They Call U Bitch.” This appears to have been part of an East Coast, West Coast rap feud, profoundly dividing the hip-hop community and fans. I remember gang bangers supporting Pac and West Coast rap even in Huntington Beach, CA. It was terrible from Los Angeles to New York, with Biggie making raps that Cali was [only] “… a great place to visit.” (See the video.)
Most people don’t know that Pac was actually from the east coast, so it’s not ironic that Pac would be shot by a leader of the South Side Crips from Los Angeles after a Mike Tyson fight in Vegas. Ironically, the head of a company called Murder Inc., “Puff Daddy,” could be convicted and spend time in Las Vegas, Nevada, for a crime that would have expired had it been carried out in New York! I hope my readers are getting all of this.
September 7, 1996 – Facts Leading to Fatal Drive-By in Vegas
These are the basic facts and conclusions as reported then.
The Hotel Fight
Following the fight, Shakur and his associates got into a fight at the hotel with a group that included Duane “Keffe D” Davis and his nephew Orlando “Baby Lane” Anderson, with whom Shakur had previous conflicts. Surveillance video showed Shakur and Knight involved in a physical altercation with Anderson near a bank of elevators.
See Suge Kick Anderson’s Video Here
The Alleged Retaliatory Drive-By Shooting
Suspects Davis and Anderson were associated with the South Side Compton Crips, a Southern California-based gang rivaling Knight’s Blood-affiliated gang, Mob Piru. Later, Tupac Shakur was shot in a fatal drive-by shooting while traveling in a black BMW driven by Death Row Records founder Marion “Suge” Knight. Shakur’s entourage consisted of about ten cars. As the story goes, they were pulling out after watching Mike Tyson fight at the MGM Grand.
One person in a white Cadillac opened fire, striking the passenger side of Knight’s car with bullets. Tupac was in the passenger seat. Pac was shot four times and at least twice in the chest. A bullet fragment grazed Knight or shrapnel from the car. When I was younger, many rappers would complain they thought Suge was involved since he wasn’t killed, too, but I don’t think so.
At a news conference on September 29, police alleged that Davis was in the Cadillac’s passenger seat. Vegas PD claims he provided a gun to a man in the back seat. They then claimed that the motive was retaliation for the earlier casino fight. Shakur was immediately taken to a hospital, where one of his lungs was removed, and he remained on a respirator in intensive care till he died six days later at 25.
November 1996 – Witness and Insider Yaki Kadafi Shot Dead
Two months after Tupac Shakur’s death, on November 10, 1996, Yafeu Fula, also known as Yaki Kadafi and a member of Shakur’s rap group Outlawz, was shot and found dead at a housing project in Orange, New Jersey, as reported by the Los Angeles Times. Fula had been traveling with bodyguards in the car behind Shakur’s on the night of the rapper’s death and may have been able to ID the killers.
March 9, 1997 – The Notorious BIG Shot Dead By Marion “Suge” Knight?
Maybe. In retaliation, it is alleged that Marion “Suge Knight” hired Bloods gang member Wardell “Poochie” Fouse to take out Smalls for $13,000, according to Detective Kading; more below about him. Kading thinks he secured a verifiable confession from Keffe D, as he faced serious charges for another crime. So he knew any deal would be off the table if caught lying. Only time will tell if this information pans out, however.
1997 – Tupac’s Mom’s Lawsuit Against Orlando Anderson
Following Tupac Shakur’s death, there were legal actions involving Tupac’s mother, Afeni Shakur, and Orlando Anderson:
- On September 12, 1997, Afeni Shakur filed a wrongful death lawsuit against Orlando Anderson, alleging that he was responsible for the shooting death of her son.
- Before this, Anderson claimed that he was assaulted by Tupac and several employees of Death Row Records in the lobby of the MGM Grand Hotel just hours before Tupac was shot. Anderson denied involvement in Tupac’s killing.
- Tragically, Orlando Anderson died two years later in an unrelated gang shooting in Compton, California.
- In the years that followed, there were legal battles and counterclaims between the estates of Tupac Shakur and Orlando Anderson. Anderson’s estate alleged that Tupac’s estate had not fulfilled a promised payment of $78,000. Anderson’s family filed a breach of contract lawsuit against Tupac’s estate.
- Eventually, the estates of Tupac Shakur and Orlando Anderson reached a settlement to resolve the lawsuits they had filed against each other. The exact terms of the settlement were not disclosed, but it marked the end of the legal disputes between the two parties.
2011 – “Diddy had Tupac killed, Retired LAPD Detective Claims”
As far back as 2011, a retired Los Angeles Police Department detective named Greg Kading alleged that music mogul Sean “Diddy” Combs paid $1 million to hire a Crips gang member to plan the murders of rapper Tupac Shakur and his manager, Marion “Suge” Knight.
Kading, who once led a special LAPD task force investigating the decades-old shootings of Shakur and The Notorious BIG (Biggie Smalls), suggests that Biggie Smalls’ killing was in retaliation for Tupac’s death.
2015 “Murder Rap” Book Based Documentary
The claims of the retired detective are featured in the documentary “Murder Rap,” based on Kading’s 2011 book of the same name, which originally premiered in 2015 and is currently available on iTunes.
February 2018 – Netflix True Crime Bombshell
In 2018, Netflix aired “Unsolved: The Tupac and Biggie Murders,” a true-crime anthology series. This series examined separate investigations into the shootings of Tupac Shakur and Biggie Smalls. This generated renewed interest in the investigations surrounding Tupac Shakur’s death and, by extension, Shakur’s estate. The investigation gained momentum and appears to have impacted the ongoing efforts to solve the Murder. But Vegas PD says they have always had this as a top priority to solve.
July 2023: Duane Davis’ Wife Raided After Admissions in Memoir
In a 2018 BET interview, Duane “Keffe D” Davis admitted to being in the vehicle’s front seat from which Tupac Shakur’s shooters fired. He also implicated his nephew, Orlando “Baby Lane” Anderson, stating that Anderson was one of two people in the backseat of the car. Davis indicated that the shots were fired from the back of the vehicle but did not explicitly name the shooter, citing adherence to the “code of the streets.”
Davis provided more details about his involvement in Tupac Shakur’s death in his 2019 memoir, “Compton Street Legend.” In the book, he stated that he broke his silence about the rapper’s killing in 2010 during a closed-door meeting with federal and local authorities. This decision came when he was 46 and facing life imprisonment on drug charges. Davis agreed to cooperate with authorities during this meeting.
In July 2023, approximately four years after the memoir’s release, Las Vegas police conducted a raid at the home of Davis’ wife in Henderson, Nevada. The police reportedly searched for items related to “the murder of Tupac Shakur.” During the search, they collected multiple items, including computers, a cellphone, a hard drive, a Vibe magazine featuring Shakur, .40-caliber bullets, two containers with photographs, and a copy of “Compton Street Legend.” These items were said to corroborate information obtained through the ongoing investigation.
September 29, 2023 – Duane Davis Arrested for Tupac Shakur Murder
Davis was arrested on September 29 while he was on a walk near his home. Chief Deputy District Attorney Marc DiGiacomo stated that Davis’ murder indictment was revealed shortly after the arrest. It was also mentioned that a grand jury had been seated in the case for “several months.”
In a press conference on the same day, Clark County District Attorney Steve Wolfson acknowledged the significance of the arrest. He noted that Tupac Shakur is a music legend, and both the local and global communities had long-awaited justice for Tupac. Wolfson emphasized that this arrest marked the first step in pursuing justice.
The fallout is unclear, but Puffy looks like he is in trouble. He could try and flee to a country that does not allow extradition. This is typical of child molesters and other scofflaws to escape justice. But it remains to be seen if Diddy would flee to a place like Switzerland or lawyer up and fight the charges after he gets arrested and deported to Las Vegas, Clark County, Nevada.
So now, let’s talk about the wrongful death case and how it could potentially play out.
Statute of Limitations Problems for Shakur Family or Estate Suing for Wrongful Death?
In New York and Nevada, the statute of limitations to sue for wrongful death cases is generally two years from the date of the person’s death. However, specific circumstances could affect the timeline in each state. Assuming a case could be brought in New York, the main difference would seem to be the discovery rule.
What is the Discovery Rule in a Wrongful Death?
The Discovery Rule is a legal doctrine that extends the statute of limitations to file a negligence claim with a court. It varies in existence and scope from state to state. It allows the clock on the statute of limitations to begin when the plaintiff (the person bringing the wrongful death claim) discovers or reasonably knows the cause of death or the relationship between it and the defendant’s alleged negligence or recklessness. New York does not broadly apply the Discovery Rule for wrongful death claims, but Nevada does.
Here, the plaintiffs will argue that they tried to sue the correct defendants they did know about, and when the police investigation revealed a confession, they could have sued Puffy. Diddy will counter that Tupac’s family already knew about his involvement from books and news articles so they could have sued him then. As such, especially in New York, he could argue that two years have passed since this was public information.
But it’s a stretch. This case could be brought in NY. Here, a Nevada court will likely side with the survivors and allow any lawsuits to proceed from the “date of discovery.” The date of discovery may not be ticking now. Right now, all we know is Puffy may be connected. Despite the swirling, perhaps untrustworthy confessions of a former gang member, we don’t see him arrested or indicted. Because of this, it could be too early to file a lawsuit against Puffy, but if it were me, I sure would! The overwhelming evidence we have investigated seems to lead to Diddy or his entourage.
It is noted that Diddy would likely be in a Clark County State Prison during the pendency of any civil death claims. Litigating a case with a defendant in prison isn’t easy, so the Shakur family must obtain top-notch legal representation against Diddy in managing such a delicate situation.
Conclusion on Suing P Diddy for Wrongful Death
Above, we have seen compelling evidence and details that Sean Puffy Combs may have been involved in the drive-by shooting death of Tupac Shakur. Whether he is convicted of Murder or not, as in the OJ case, the victims can still sue Diddy for wrongful death and perhaps as a survival action. Statutes of limitations in the murder case, as well as the wrongful death claims, were discussed. Do you think a lawyer can prove wrongdoing to the judge or jury that Diddy and the Crips worked together to take out Pac? Is Puffy a murderer? If you think we missed something, put it in the comments.