A federal judge in Manhattan dismissed journalist Michael Wolffâs lawsuit against First Lady Melania Trump on Friday, rejecting his effort to obtain a court declaration that would have blocked her from pursuing a threatened $1 billion defamation claim.
U.S. District Judge Mary Kay Vyskocil, sitting in the Southern District of New York, said Wolffâs case was a âcontortedâ attempt to short-circuit ordinary litigation. âThat is not how the federal courts work,â she wrote in a 45-page opinion. The judge accused Wolff of an âinappropriate level of tactical gamesmanshipâ and said the court would not be âconscripted to oversee an abusively presented spat.â
Vyskocil acknowledged that the two sides have a âreal dispute.â She found that federal court had jurisdiction because the parties are citizens of different states and the threatened claim exceeds $1 billion. She nevertheless declined to exercise that jurisdiction, dismissing the case so it can âbe litigated like any other.â
Wolff filed the suit in New York state court in October after receiving a letter from Melania Trumpâs lawyer, Alejandro Brito. The letter demanded that Wolff retract statements about the first lady and Jeffrey Epstein and warned that she would have âno alternativeâ but to sue if he refused. Brito later removed the case to federal court and sought dismissal or transfer to Florida.
The dispute centers on public comments Wolff made linking Melania Trump to Epstein, the financier who died in jail in 2019 while awaiting trial on child sex-trafficking charges. The first lady has denied any association with Epstein. In an April news conference she said, âThe lies linking me with the disgraceful Jeffrey Epstein need to end today,â and accused critics of âmean-spirited attempts to defame my reputation.â
Her lawyers have said Wolffâs statements caused âoverwhelming reputational and financial harm.â A spokesperson for the first lady said after the ruling that she âis proud to continue standing up to, and fighting against, those who spread malicious and defamatory falsehoods as they desperately try to get undeserved attention and money from their unlawful conduct.â
Wolff, author of several books about President Donald Trump, argued that the Trumps have used expensive legal threats âto silence their speech, to intimidate their critics generally, and to extract unjustified payments.â His complaint said some of his remarks were taken out of context and that others were protected opinion, including a characterization of the Trumpsâ marriage as a âshamâ or âtrophyâ marriage. He also said he never accused the first lady of criminal conduct tied to Epstein.
Last summer, The Daily Beast retracted an article headlined âMelania Trump âVery Involvedâ in Epstein Scandal: Author,â which was based on an interview with Wolff, after receiving a letter from Brito. In that interview, Wolff said the first lady was âbehind the scenesâ dealing with White House handling of the matter but was not involved criminally.
Vyskocil, a Trump appointee, did not rule on whether Wolffâs statements were defamatory. She said Wolff had raced to the courthouse in New York in hopes of invoking that stateâs more defendant-friendly anti-SLAPP law before Melania Trump could file in Florida. The proper course, the judge wrote, is for the parties to litigate the threatened claim in the ordinary sequence, not through a preemptive declaratory-judgment action.
The dismissal leaves Melania Trump free to proceed with a defamation suit if she chooses. It does not resolve the underlying factual or First Amendment questions. Wolff has said the ruling, because it did not reach the merits, still leaves legal avenues open. Melania Trumpâs team has framed the outcome as a rejection of what it called forum-shopping and an abuse of the declaratory-judgment process.
The case sits at the intersection of high-profile politics, press freedom and defamation law. Courts generally disfavor lawsuits filed solely to obtain an advance ruling that a future claim will fail. Vyskocilâs decision tracks that principle: the parties may have a genuine controversy, she said, but they must present it through the same procedures that apply to everyone else.
