A federal judge in Manhattan on Wednesday dismissed a lawsuit filed by journalist Michael Wolff against First Lady Melania Trump, eliminating his attempt to block her from pursuing a $1 billion defamation claim over statements he made regarding her alleged connection to Jeffrey Epstein.
Judge Mary Kay Vyskocil ruled that Wolff’s action constituted an inappropriate procedural maneuver. The decision clears the way for Trump’s legal team to proceed with her planned lawsuit without the complication of Wolff’s preemptive filing in state court.
Vyskocil characterized Wolff’s lawsuit as a “contorted” approach and said it was “not how federal courts work.” She stated from the bench that she would not be “drafted to oversee an abusively presented spat,” according to court filings, yet acknowledged that both parties had legitimate grievances at the heart of the dispute.
What Happened
The legal sequence began when Melania Trump’s attorney, Alejandro Brito, sent Wolff a cease-and-desist letter last year demanding he remove specific statements and threatening a lawsuit if he did not comply. Wolff responded by filing suit in New York state court in October, seeking a declaration that his statements were protected speech and attempting to establish that he bore no legal liability.
Brito then moved the case to federal court, where Vyskocil assumed jurisdiction. Rather than ruling on the merits of Wolff’s claims, the judge exercised what is known as discretionary dismissal. She determined that while federal courts had technical authority over the dispute, she would decline to hear it and instructed the matter be “litigated like any other”—meaning Trump could now sue Wolff in state court without his preemptive federal filing standing in the way.
Vyskocil described Wolff’s maneuver as “an inappropriate level of tactical gamesmanship.” In her ruling, she recognized the underlying dispute between the parties as genuine but declined to mediate it through a federal preemptive lawsuit.
The Reaction
A spokesperson for Melania Trump issued a statement saying the first lady “is 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.”
Wolff’s claims centered on statements he made linking Trump to Epstein, the financier who died in custody in 2019 awaiting trial on child sex trafficking charges. In his federal filing, Wolff argued that some of his statements were taken out of context and that others constituted protected opinion—specifically referencing comments he made about the Trump marriage being a “sham” or “trophy marriage.”
Trump’s legal team has asserted that Wolff’s statements caused her “overwhelming reputational and financial harm.” The Daily Beast retracted an article in summer 2025 titled “Melania Trump ‘Very Involved’ in Epstein Scandal: Author” after receiving a letter from Brito, though Wolff clarified in subsequent interviews that he had reported Trump was working “behind the scenes” at the White House but had no involvement in any criminal activity.
Trump herself addressed the allegations in an April press conference, stating, “The lies linking me with the disgraceful Jeffrey Epstein need to end today.” She added that those making such claims were “devoid of ethical standards, humility, and respect” and rejected what she described as “mean-spirited attempts to defame my reputation.”
What This Means
The dismissal removes a procedural obstacle from Trump’s path to filing a defamation action. Wolff had argued in his federal filing that the president and first lady “have made a practice of threatening those who speak against them” with costly legal suits designed to silence critics and extract payments. Now, Trump’s planned $1 billion lawsuit can proceed without the complication of Wolff’s preemptive federal claim.
The case reflects broader tensions over the boundaries of defamation law, protected speech, and the use of civil litigation in disputes involving public figures. Vyskocil’s ruling suggests federal courts may be reluctant to serve as gatekeepers for disputes that can be resolved through conventional state court litigation, even when procedurally complex questions arise.
