A federal judge has dismissed a preemptive defamation lawsuit filed by author Michael Wolff against First Lady Melania Trump, ruling that the case was improperly brought and criticizing its tactical approach.
In a 45-page opinion issued Friday, U.S. District Judge Mary Kay Vyskocil of the Southern District of New York declined to exercise jurisdiction, even while acknowledging a genuine dispute between the parties. Judge Vyskocil, appointed by President Donald Trump, described Wolff’s filing as a “contorted” effort marked by an “inappropriate level of tactical gamesmanship.”
“While Plaintiff and the First Lady have a real dispute, they must litigate it according to the same procedures as everyone else,” Vyskocil wrote. “Plaintiff asks for a declaration that, if the First Lady sues him, he deserves to win. That is not how the federal courts work.”
The dispute originated from Wolff’s public comments linking Melania Trump to the late financier Jeffrey Epstein, who died in federal custody in 2019 while awaiting trial on sex trafficking charges. In response, Melania Trump’s attorney, Alejandro Brito, sent Wolff a demand letter requesting a retraction of the statements and warning of potential defamation litigation seeking substantial damages.
Instead of awaiting a lawsuit, Wolff filed preemptively in New York state court, seeking a judicial declaration that his remarks were protected by the First Amendment or had been taken out of context. He also alleged that the Trump family has a pattern of using litigation to discourage criticism. The case was subsequently transferred to federal court.
A spokesperson for the First Lady welcomed the dismissal, stating that Melania Trump remains committed to defending her reputation against false and defamatory claims.
Earlier this year, Melania Trump publicly rejected any association with Epstein or his associate Ghislaine Maxwell. She stated she had never visited Epstein’s private island, flown on his aircraft, or possessed any knowledge of his criminal activities, labeling the allegations as entirely false and defamatory.
Friday’s ruling does not resolve the underlying merits of the potential defamation claims. It leaves open the possibility that Melania Trump could pursue legal action in another jurisdiction. Wolff has defended the accuracy of his reporting and maintained that the legal pressure represents a broader effort to intimidate journalists and critics.
The decision underscores procedural limits on anticipatory lawsuits in federal court and highlights ongoing tensions between public figures and authors over reputational matters.
