A federal judge in Manhattan dismissed author Michael Wolff’s lawsuit against First Lady Melania Trump on Friday, rejecting his attempt to use the courts to block a threatened $1 billion defamation action before it was ever filed.
US District Judge Mary Kay Vyskocil, a Trump appointee, issued a 45-page ruling describing Wolff’s legal strategy as a “contorted” exercise in procedural gamesmanship that is not how the federal courts work.
The dispute centres on comments Wolff made in interviews, social media posts, and content published by The Daily Beast concerning Melania Trump’s alleged associations with Jeffrey Epstein, the convicted sex offender who died in federal custody in 2019 while awaiting trial on trafficking charges.
Wolff filed the lawsuit in New York state court in October 2025 after receiving a letter from Melania Trump’s attorney, Alejandro Brito, warning that she would be left with no alternative but to pursue legal action if he did not retract statements the letter said had caused her overwhelming reputational and financial harm.
Rather than wait for a defamation case to be brought against him, Wolff chose to file an anti-SLAPP claim in New York seeking a declaration that his remarks were not defamatory and that any future lawsuit would constitute a violation of New York’s protections for public discourse.
Brito subsequently had the case transferred to federal court and moved for dismissal or transfer to a federal court in Florida.
Judge Vyskocil ruled that while federal jurisdiction existed, she was declining to exercise it, accusing Wolff of engaging in textbook bad-faith forum shopping by initiating proceedings in New York before Melania Trump had even commenced any action in Florida.
Vyskocil said she would not be drawn into overseeing what she called an abusively presented dispute, insisting that both parties must litigate any genuine claims on the same procedural footing as anyone else.
Wolff has maintained throughout that his statements referred to Melania Trump’s handling of Epstein-related matters and did not accuse her of participation in any crimes, and his legal team has indicated he views the anti-SLAPP framework as the appropriate vehicle for protecting press freedom.
A spokesperson for Melania Trump said she is proud to continue standing up to those who spread malicious and defamatory falsehoods, signalling that a substantive defamation case in Florida remains a live possibility.
