'Should not be litigated here': Michael Wolff harshly upbraided by federal judge for 'preemptively' filing lawsuit against Melania Trump over Epstein dispute

A national justice successful Manhattan has handed archetypal woman Melania Trump a important triumph successful tribunal by dismissing a lawsuit against her filed by governmental biography writer Michael Wolff.

In a 45-page sentiment and order connected Friday, U.S. District Judge Mary Kay Vyskocil, who was appointed by President Donald Trump during his archetypal term, enactment the kibosh connected a preemptive suit filed by Wolff.

In October 2025, the writer filed an anti-SLAPP lawsuit against Melania Trump – alleging that a "threat letter" helium received from her attorneys was "[f]or each intents and purposes" a ailment that outlines a fig of would-be defamation claims against him.

Wolff has penned a fig of bestselling books astir Trump and has been a vocal professional of the president's alleged ties to Jeffrey Epstein, on with Melania Trump's alleged connections to the deceased pedophile financier. In interviews and his ain complaint, Wolff has said: "First Lady Melania could beryllium the missing nexus successful President Trump's ties to convicted enactment offender Jeffrey Epstein."

In a menace letter, Melania Trump's attorneys said Wolff indispensable "issue an apology for the false, defamatory, disparaging, misleading, and inflammatory statements" astir her and "demanded an connection of wealth to compensate" for the "overwhelming reputational and fiscal harm" helium caused her, according to Wolff's ain lawsuit.

That missive further cautioned that if Wolff did "not comply" with those demands by the extremity of concern connected Oct. 21, 2025, Melania Trump would initiate ineligible enactment to the tune of $1 cardinal successful damages.

But, portion Melania Trump's threatened defamation suit has yet to materialize, Wolff himself sued connected the ground that her lawyer missive was issued "for the intent of harassing, intimidating, punishing, oregon different maliciously inhibiting Mr. Wolff's escaped workout of speech."

Wolff's suit was filed nether the New York State anti-SLAPP — oregon strategical suit against nationalist information — law, which tin enactment a speedy extremity to a defamation suit if a tribunal determines the idiosyncratic complaining of defamation is really trying to chill escaped speech.

The judge, however, rubbished Wolff's effort arsenic excessively much, excessively soon.

"In this case, a chronicler of the First Family sues the First Lady due to the fact that she threatened to writer him for defamation," the sentiment begins. "While Plaintiff and the First Lady person a existent dispute, they indispensable litigate it according to the aforesaid procedures arsenic everyone else. Plaintiff asks for a declaration that, if the First Lady sues him, helium deserves to win. That is not however the national courts work."

Wolff besides complains astir the suit being removed to national tribunal – which was done connected Melania Trump's petition – and the justice likewise has nary patience for the author's arguments there.

"[W]hile it whitethorn person started successful authorities court, this lawsuit was decently removed," the sentiment goes on. "Plaintiff and the First Lady are citizens of antithetic states, and the suit she threatened seeks a cardinal dollars successful damages."

The justice besides takes the accidental to poke astatine some sides.

"There are galore features of this lawsuit that marque it complicated: the prominence of the personalities involved, the scandalizing contented of the underlying statements, and, frankly, an inappropriate level of tactical gamesmanship," the sentiment continues. "But the result is simple. The Court volition not beryllium conscripted to oversee an abusively presented spat and truthful declines to scope the merits here."

Part of the simplicity for Vyskocil is the information that determination is nary existent defamation suit that has been filed against Wolff.

"On the merits, the basal contented present is whether Plaintiff's nationalist statements astir the First Lady were defamatory," the justice observes. "But that question, nevertheless overmuch attraction it whitethorn person received successful the media, is not yet earlier the Court."

The tribunal outlines the disjointed quality of the case, astatine length:

This lawsuit is presented to the Court successful a somewhat contorted posture: A would-be defamation suspect sues a would-be defamation plaintiff successful New York authorities court. He seeks a declaration that statements identified successful a request missive threatening litigation nether Florida instrumentality are not defamatory, and, further, that immoderate specified litigation would violate—or, perhaps, has violated already—New York's anti-SLAPP law. Thereafter, the would-be defamation plaintiff removes the enactment to national court, and moves to dismiss.

But, Vyskocil says, the "would-be" quality of the claims and allegations involves the aboriginal – and that is neither litigable nor proper.

"Plaintiff whitethorn oregon whitethorn not person defenses to the First Lady's would-be assertion of defamation," the sentiment goes on. "Indeed, helium whitethorn oregon whitethorn not have—or travel to have—anti-SLAPP claims of his own. The Court takes nary presumption connected these possibilities. The Parties are escaped to prosecute successful bully religion immoderate claims they wish. But it is disingenuous for Plaintiff to asseverate that helium had 'no choice' but to preemptively record this enactment successful New York."

The justice casts Wolff's claims arsenic a "simulated adjudication of a would-be Florida-based defamation suit" successful which she would person to "generate" a "needless" determination connected the scope of New York law.

"To scope the merits present would beryllium an maltreatment of the judicial strategy and a discarded of its resources," Vyskocil chides.

For each the rancor, the justice says, the lone genuinely salient and unrecorded contented was the substance of removal to national court.

"The First Lady was entitled to person Plaintiff's enactment against her heard by a national tribunal according to national procedures," the sentiment concludes. "That enactment does interest a unrecorded lawsuit oregon controversy, but it is 1 that should beryllium litigated according to the 'traditional procedures for adjudicating' speech-tort cases betwixt backstage parties. Accordingly, it should not beryllium litigated here. Because this lawsuit presents a existent dispute—one betwixt citizens of antithetic states—this Court has taxable substance jurisdiction. The Court, however, declines to workout that jurisdiction. Instead, based connected prudential abstention, it dismisses this lawsuit to beryllium litigated similar immoderate other."

Chris Perez contributed to this report.