NEW YORK — A federal judge has dismissed author and journalist Michael Wolff’s preemptive lawsuit against first lady Melania Trump, leaving unresolved the central question at the heart of the escalating legal dispute over statements involving Melania Trump and Jeffrey Epstein.
U.S. District Judge Mary Kay Vyskocil of the Southern District of New York issued a 45-page ruling on May 22, determining that Wolff’s attempt to obtain a court declaration before a conventional defamation lawsuit was filed was not the appropriate vehicle for resolving the dispute.
The judge acknowledged that the parties have a genuine legal controversy but declined to determine whether Wolff’s statements were defamatory or protected speech.
Instead, Vyskocil concluded that the matter should proceed through the ordinary legal process if a defamation action is ultimately pursued. She criticized what she characterized as an “inappropriate level of tactical gamesmanship” surrounding Wolff’s litigation strategy.
⚖️ Dispute Focuses on Epstein-Related Statements
The case grew out of public statements by Wolff concerning Melania Trump and Epstein, the convicted sex offender who died in federal custody in 2019 while awaiting trial on federal sex-trafficking charges.
Melania Trump’s legal representatives had demanded that Wolff retract statements they considered defamatory and indicated that a potential lawsuit could seek substantial damages.
Rather than wait for a conventional defamation case, Wolff filed his own action seeking a judicial declaration regarding whether his statements were legally protected.
The lawsuit was initially filed in New York state court before being transferred to federal court in December 2025. The case is identified as Wolff v. Trump, No. 1:25-cv-10752.
🚨 The Judge Did Not Decide Who Was Right
The dismissal does not mean the court found Wolff’s statements defamatory.
It also does not establish that the statements were protected by the First Amendment.
Instead, the judge declined to reach those substantive questions.
Judgment was entered in favor of Melania Trump on May 26. Wolff has since appealed the dismissal to the U.S. Court of Appeals for the Second Circuit, where the case is listed as No. 26-1674.
His opening brief is currently scheduled for October 1, 2026.
For now, the underlying dispute remains unresolved. Any future defamation case would have to address the statements themselves, their factual basis and the applicable legal standards.
The ruling therefore represents a procedural victory for Melania Trump, but it is not a final judicial determination concerning the truth, falsity or legal status of Wolff’s disputed statements.
