Melania Trump Demands Sanctions Against Author Over Jeffrey Epstein Link Claims, New Court Filings Show
First lady Melania Trump has intensified her legal battle with author and journalist Michael Wolff, asking a federal judge to sanction him and his attorneys following the dismissal of his lawsuit against her.
In a memorandum filed in the U.S. District Court for the Southern District of New York, Trump’s lawyers requested reimbursement for the costs and reasonable attorneys’ fees she incurred while defending herself against Wolff’s legal action. Her team argues that the lawsuit relied on unsupported factual assertions, advanced a legally defective claim, and transformed a private legal dispute into a public fundraising campaign.
The sanctions request does not ask the court to decide whether Wolff’s controversial statements about Trump and convicted sex offender Jeffrey Epstein were defamatory. Instead, it focuses on how Wolff and his attorneys allegedly used the federal court process.
That distinction is critical. Although Wolff’s earlier lawsuit has been dismissed, the truth or falsity of the underlying allegations has not been decided at trial.
Melania Trump Files a 26-Page Motion for Sanctions
The dispute entered a new phase when Trump’s attorneys filed a corrected memorandum on July 21, 2026, after submitting the initial sanctions motion around midnight on July 20.
The document asks U.S. District Judge Mary Kay Vyskocil to sanction Wolff under Rule 11 of the Federal Rules of Civil Procedure. It also seeks sanctions against his lawyers under Rule 11 and 28 U.S.C. §1927.
Trump’s legal team accuses Wolff and his attorneys of turning the threatened defamation case into a “fundraising drive and a political spectacle.” The filing claims they pursued a lawsuit that lacked a proper legal basis, presented unsupported information about Trump’s private life, and continued advancing those arguments after receiving a formal warning.
Under Rule 11, lawyers and litigants generally certify that court filings are not being presented for an improper purpose and that their factual and legal claims have adequate support. Section 1927 separately permits courts to hold attorneys personally responsible for excess costs caused when they unreasonably and vexatiously multiply legal proceedings.
How the Michael Wolff and Melania Trump Dispute Began
The conflict grew out of public statements Wolff made concerning Melania Trump, President Donald Trump and Epstein.
Trump’s attorneys say Wolff falsely suggested that she had been deeply connected to Epstein’s social world and misconduct. They also objected to claims concerning how she met her husband, the nature of the Trump marriage and an alleged encounter involving Epstein’s private aircraft.
On October 15, 2025, Trump’s lawyer sent Wolff a pre-action demand letter under Florida law. The letter called for an apology and retraction and warned that she was prepared to pursue a defamation claim if Wolff refused.
Six days later, on October 21, Wolff filed a lawsuit in New York state court. Rather than waiting for Trump to sue him, he sought a declaration that his statements were not defamatory and that a future lawsuit against him could violate New York’s anti-SLAPP protections.
Anti-SLAPP laws are intended to protect public participation and expression from lawsuits primarily designed to silence criticism. Wolff maintained that Trump’s threatened $1 billion defamation action represented an attempt to intimidate him and discourage scrutiny of the Trump family.
Trump’s lawyers rejected that portrayal. They argued that Wolff was attempting to control the timing and location of a lawsuit that had not yet been filed.
Trump’s Lawyers Accuse Wolff of Using the Case to Raise Money
One of the most prominent arguments in the sanctions motion concerns Wolff’s public fundraising.
The filing says Wolff launched a crowdfunding campaign to finance his legal fight and collected more than $836,000 while promoting the case through his media platforms. Trump’s attorneys argue that the campaign demonstrates the lawsuit was being used for political, commercial and publicity purposes rather than as a conventional request for judicial relief.
Wolff presented the campaign differently. He told supporters that the lawsuit could provide subpoena power and potentially require Donald and Melania Trump to answer questions under oath about Epstein.
The new motion argues that those public promises reveal an improper strategy. Trump’s team says Wolff was not merely seeking protection from a threatened defamation case but attempting to create a vehicle for discovery, publicity and additional fundraising.
The court has not ruled that the fundraiser was unlawful. Trump’s attorneys instead use its existence as evidence that the litigation had an improper purpose.
Federal Judge Dismissed Wolff’s Lawsuit in May
The case moved from New York state court to federal court on December 29, 2025. Trump then sought its dismissal.
On May 22, 2026, Judge Vyskocil dismissed Wolff’s lawsuit. She concluded that the parties had a genuine disagreement but that Wolff could not use the federal courts to obtain advance approval of his defense before Trump filed a defamation case.
The judge criticized what she described as an inappropriate degree of tactical maneuvering. She said the court would not oversee an improperly presented dispute and described Wolff’s effort to secure his preferred forum as “textbook bad-faith forum-shopping.”
The court did not declare Wolff’s statements true or false. It also did not issue a final judgment on whether Trump could succeed in a future defamation lawsuit.
Instead, the dismissal was largely procedural. The judge found that Wolff was trying to use a declaratory judgment action to preempt a potential case that belonged to Trump, as the prospective plaintiff, to file through ordinary legal procedures. Wolff has appealed the dismissal to the U.S. Court of Appeals for the Second Circuit.
Judge Warned Trump That Sanctions Carry a High Burden
Although the dismissal gave Trump a significant procedural victory, Judge Vyskocil expressed reservations about continuing the litigation through a sanctions motion.
During a July 1 conference, the judge reminded Trump’s attorneys that the original case was closed and questioned whether pursuing sanctions would be worth the additional cost and judicial resources.
She also said Trump would face a “very high burden” and would need clear evidence that Wolff’s lawsuit was both baseless and pursued in bad faith. At the same time, the judge acknowledged that she could not prevent a party from filing a motion genuinely believed to be warranted.
Trump’s legal team decided to proceed.
The new filing draws heavily on the language of Vyskocil’s dismissal order, arguing that the court has already identified serious defects in Wolff’s tactics, factual submissions and use of the Declaratory Judgment Act.
Sanctions Motion Targets Claims About Trump’s Private Life
Trump’s lawyers also object to statements introduced while Wolff challenged her claim that Florida, rather than New York, was her legal domicile.
The question mattered because federal jurisdiction depended partly on the parties being citizens of different states. Trump’s team pointed to her Florida voter registration, driver’s license, residence designation and voting history.
Wolff’s attorneys argued that her formal Florida connections did not necessarily establish where she truly lived. In support of that argument, they submitted assertions concerning her marriage, her relationship with President Trump, her son, her father and her personal living arrangements.
The sanctions motion describes those submissions as irrelevant speculation intended to embarrass the first lady. It argues that the statements did not provide reliable evidence about domicile and should never have been placed in a public federal filing.
Judge Vyskocil had already criticized portions of that material in her dismissal ruling, describing the submission as resembling tabloid speculation rather than a focused jurisdictional presentation.
What Melania Trump Is Asking the Court to Award
Trump has not yet requested a specific dollar amount. Her motion asks the court to sanction Wolff under Rule 11, sanction his counsel under both Rule 11 and Section 1927, and award her the reasonable costs and attorneys’ fees generated by the proceedings.
The filing says Trump will submit a detailed accounting of those expenses only if the judge decides that sanctions should be imposed.
Possible sanctions could therefore involve Wolff, his attorneys, or both, depending on the court’s findings. However, the motion itself does not guarantee that any fees will be awarded.
The judge must first determine whether the challenged conduct crossed the line from aggressive legal advocacy into sanctionable abuse.
Wolff Denies Accusing Melania Trump of Epstein’s Crimes
Wolff has maintained that his statements did not accuse Melania Trump of participating in Epstein’s criminal activity.
In his dismissed complaint, he argued that some comments had been taken out of context, while others reflected protected opinion or commentary about the Trumps’ social circle, marriage and response to the Epstein controversy.
He also argued that the threat of an enormous defamation claim could discourage journalists and critics from exercising their First Amendment rights.
Trump has firmly denied having a meaningful association with Epstein. In an April statement, she said she had never been his friend and rejected claims connecting her to his criminal conduct. She acknowledged that she and Donald Trump sometimes attended events where Epstein was also present, describing that overlap as part of social life in New York and Palm Beach.
These competing accounts remain disputed. No court has ruled that Wolff proved his allegations, and no court has ruled on the merits that his public statements legally defamed Trump.
What Happens Next in the Melania Trump Sanctions Case
The federal docket set August 17, 2026, as the deadline for Wolff’s opposition to the sanctions request. Trump’s reply is due by August 28.
Judge Vyskocil will then decide whether the written submissions are sufficient or whether additional proceedings are required.
Several outcomes remain possible. The judge could deny the motion entirely, sanction Wolff, sanction one or more attorneys, award a portion of Trump’s legal costs, or impose another remedy intended to deter future misconduct.
The decision will be separate from Wolff’s appeal and separate from any future defamation action Trump may choose to file.
For now, the latest filing represents an effort by Melania Trump to convert her procedural victory into financial and professional consequences for the author and legal team that sued her. Whether the judge views Wolff’s conduct as sanctionable misconduct or merely unsuccessful litigation will determine how far this increasingly bitter legal confrontation proceeds.
