A federal judge has dismissed a lawsuit filed by author Michael Wolff against First Lady Melania Trump, ruling that the case was brought prematurely and did not warrant federal court intervention.
In a 45-page opinion issued on May 22, 2026, U.S. District Judge Mary Kay Vyskocil of the Southern District of New York declined to exercise jurisdiction over the matter. While acknowledging a genuine underlying dispute between the parties, Judge Vyskocil determined that Wolff’s request for a declaratory judgment—seeking a preemptive ruling that he would prevail in any potential defamation suit by Melania Trump—was not an appropriate use of the federal courts.
“While Plaintiff and the First Lady have a real dispute, they must litigate it according to the same procedures as everyone else,” Judge 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 controversy originated from public statements by Wolff connecting Melania Trump to the late financier and convicted sex offender Jeffrey Epstein. In response, Melania Trump’s attorney, Alejandro Brito, sent Wolff a demand letter calling for a retraction and warning of a potential defamation lawsuit seeking substantial damages.
Instead of waiting for formal legal action, Wolff filed suit in New York state court, seeking a declaratory judgment that his statements were protected under the First Amendment or had been misinterpreted. He also highlighted what he described as the Trump family’s history of using litigation to deter criticism. The case was later removed to federal court.
Following the dismissal, a spokesperson for Melania Trump expressed satisfaction with the outcome. The First Lady has consistently denied any association with Epstein or Ghislaine Maxwell, stating she never visited Epstein’s private island, never flew on his aircraft, and had no knowledge of his criminal activities.
Importantly, the court’s decision rested solely on procedural grounds, including concerns over forum shopping and tactical timing, and did not address the merits of any potential defamation claim. This leaves the door open for Melania Trump to pursue litigation in an appropriate forum.
Wolff, known for his critical books on the Trump family, has defended his reporting and portrayed the case as raising broader questions about free speech and press protections. The ruling underscores the limits of using declaratory judgments to preempt defamation disputes and emphasizes that even high-profile parties must follow standard legal procedures.
