A federal judge in Manhattan dismissed a preemptive lawsuit filed by journalist Michael Wolff against First Lady Melania Trump on Tuesday, clearing the path for Trump’s separate $1 billion defamation claim to move forward in state court.
Wolff had sought to block Trump from pursuing her defamation case by filing in federal court, calling her threatened legal action an abuse of power. The judge, however, found his approach improper and declined to intervene.
What Happened
Manhattan Federal Judge Mary Kay Vyskocil dismissed Wolff’s October lawsuit, finding it an inappropriate strategic maneuver. “It’s an inappropriate level of tactical gamesmanship,” Vyskocil said during the ruling. She characterized the case as “contorted” and said she would not be “drafted to oversee an abusively presented spat,” while acknowledging that both parties have a legitimate underlying dispute.
The sequence began last year when Trump’s legal team issued a demand letter to Wolff, instructing him to delete certain statements he had made regarding Trump’s alleged association with Jeffrey Epstein and threatening a $1 billion lawsuit if he refused. Wolff responded by filing suit in state court to preempt her action, but Trump’s lawyer, Alejandro Brito, moved the case to federal court. Vyskocil determined that while federal jurisdiction technically existed, she would decline to exercise it and send the matter back to state court for resolution.
The Reaction
A spokesperson for Melania Trump said 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.” Trump’s legal team has previously stated that Wolff’s statements caused her “overwhelming reputational and financial harm.”
The first lady has repeatedly denied any connection to Epstein, who died in custody in 2019 while facing charges related to sex trafficking. “The lies linking me with the disgraceful Jeffrey Epstein need to end today,” Trump said at an April press conference. “The individuals lying about me are devoid of ethical standards, humility, and respect.”

In his lawsuit, Wolff contended that some of his statements were either taken out of context or constituted protected opinion, including his characterization of the Trumps’ marriage as a “sham” and “trophy marriage.” He argued that he never explicitly accused Trump of involvement in any criminal conduct related to Epstein. The Daily Beast retracted an article based on a Wolff interview last summer after receiving a letter from Brito, with Wolff later clarifying that he had reported Trump was “behind the scenes” addressing the matter at the White House, not engaged in criminal activity.
What This Means
Wolff had argued in his filing that the president and first lady have established a pattern of using costly litigation to silence critics and extract settlements, describing the tactic as reminiscent of authoritarian pressure. The dismissal, however, leaves Melania Trump’s defamation claim to proceed through the state court system, where judges will ultimately decide whether Wolff’s statements crossed the line from protected speech into actionable falsehoods.
Republican and Democratic lawmakers previously weighed in on the matter. Republican Representative Nancy Mace praised Melania Trump’s public statements, while Democratic Representative Robert Garcia called for congressional hearings into the broader questions surrounding Epstein’s connections. During her press conference, Trump urged Congress to take legislative action and allow victims to testify under oath.
The case now returns to state court, where the substantive dispute over Wolff’s statements and their impact on Trump’s reputation will be litigated according to New York defamation law. The outcome will likely hinge on whether a jury determines the statements were provably false and caused demonstrable harm.
