Donald Trump’s defamation lawsuit against Dow Jones, News Corp, Rupert Murdoch and two Wall Street Journal reporters over a July 2025 article about a birthday letter to Jeffrey Epstein was dismissed with prejudice on October 31, 2026. The judge ruled that Trump had not plausibly alleged actual malice and did not decide whether Trump wrote the letter; the case is not a class action, and there is nothing to claim.
Individual Lawsuit · Not a Class Action
This article describes an individual defamation lawsuit and the court order dismissing it. Statements attributed to the complaint are the plaintiff’s allegations. The court did not decide whether the Journal’s article was true or false, or whether Trump wrote the letter it described. There is nothing for members of the public to claim. This page is general information and is not legal advice.
What Happened
U.S. District Judge Darrin P. Gayles granted the defendants’ motion to dismiss Trump’s amended complaint on October 31, 2026, in Trump v. Dow Jones & Company, Inc., No. 1:25-cv-23232, in the U.S. District Court for the Southern District of Florida. The defendants were Dow Jones, which publishes The Wall Street Journal; its parent, News Corp; News Corp director and majority owner Rupert Murdoch; News Corp chief executive Robert Thomson; and Khadeeja Safdar and Joseph Palazzolo, the reporters who wrote the article.The judge held that the amended complaint did not allege facts making it plausible that the defendants published the article knowing it was false or with reckless disregard for whether it was. Because it was Trump’s second attempt to plead the claims, he dismissed them with prejudice, which means they cannot be refiled in that court. The docket lists the case as terminated on October 31.
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The Article and the Lawsuit
On July 17, 2025, the Journal published an article reporting that Ghislaine Maxwell collected letters from Epstein’s friends and associates for a leather-bound album marking his 50th birthday in 2003, and that one of the letters bore Trump’s name. The article described the page as typewritten text framed by a hand-drawn outline of a naked woman, with a signature reading “Donald,” and it said it was not clear how the letter was prepared. It also quoted Trump denying that he wrote the letter or drew the picture.Trump sued the next day, July 18, 2025. His complaint alleged that the letter is fake, that he did not write, draw or sign it, and that the defendants published the story anyway after his lawyers told them it was false; the amended complaint added that press secretary Karoline Leavitt and Trump himself had also denied it before publication. It brought two counts, defamation per se and defamation per quod, each demanding at least $10 billion. The defendants moved to dismiss.
On September 8, 2025, the House Oversight Committee released documents it had subpoenaed from Epstein’s estate, including a copy of the birthday album with a page matching the article’s description. Trump disputes that the page is authentic, and the judge declined to consider the album or that page in ruling on either motion to dismiss.
Why the Judge Dismissed It
A public figure suing for defamation has to show actual malice: that the publisher knew a statement was false or acted with reckless disregard for whether it was. Under Eleventh Circuit precedent, a public figure has to allege facts that make actual malice plausible in the complaint itself, before discovery begins. The order found that the amended complaint fell short of that standard on each theory it advanced:- The denial. Publishing over a subject’s denial does not show actual malice on its own, the judge wrote, and the article reported Trump’s denial rather than leaving it out.
- The investigation. The order pointed to the outreach described in the article itself: the reporters sought comment from Trump and his team, the Justice Department, the FBI, Maxwell and her lawyer, and others who contributed to the album. A failure to investigate is not actual malice without facts showing the defendants deliberately avoided the truth.
- Maxwell. Trump alleged that Maxwell later told the Justice Department she did not remember him submitting a letter. The judge noted that interview took place after the article was published, so the reporters could not have relied on it.
- The omissions. Choices about which details to include, and whether to publish an image of the letter, do not establish actual malice.
- The Journal’s follow-up. A September 8, 2025 Journal article comparing the letter with Trump’s known signatures and drawings did not show the defendants knew or suspected the first story was false.
The judge added that the amended complaint contained no specific allegations about Thomson at all, and that the defamation per quod count would have failed regardless because it did not allege special damages, the concrete out-of-pocket losses that kind of claim requires. Reputational harm alone does not qualify.
The order did not decide whether the article was true or whether its statements were defamatory. Whether Trump wrote the letter, the judge wrote, is a question of fact that cannot be resolved on a motion to dismiss.
How the Case Got Here
- July 18, 2025: Trump filed the complaint in federal court in Miami.
- September 22, 2025: The defendants moved to dismiss with prejudice.
- December 9, 2025: Judge Gayles heard argument on the motion.
- April 13, 2026: The judge dismissed the original complaint, finding it did not plausibly allege actual malice, and allowed Trump to amend. He later denied Trump’s request for limited discovery on actual malice before amending.
- May 27, 2026: Trump filed an amended complaint with the same two counts.
- June 10, 2026: The defendants moved to dismiss again, with prejudice.
- August 5, 2026: The judge heard argument on the second motion.
- October 31, 2026: The judge dismissed the amended complaint with prejudice.
Legal Fees and What Comes Next
The defendants asked the court to order Trump to pay their attorneys’ fees under Florida’s or New York’s anti-SLAPP law, statutes that allow fee awards against lawsuits brought over speech on matters of public concern. The judge wrote that he agreed the defamation claims lack merit, but did not rule on fees because the parties had not fully briefed which state’s law applies, and several federal courts have held that New York’s statute does not allow a fee request by motion in federal court. He kept jurisdiction over the issue and gave the defendants 30 days from the order to file a fee motion that addresses the choice of law.Trump can ask the U.S. Court of Appeals for the Eleventh Circuit to review the dismissal. As of November 1, 2026, the docket showed no notice of appeal and no public statement about one in the court record.
Questions
Did the court decide whether Trump wrote the Epstein birthday letter?
No. Judge Darrin P. Gayles wrote that whether Trump authored the letter is a question of fact that cannot be decided on a motion to dismiss. He also declined to rule on whether the Journal’s article was true or defamatory. The dismissal rests on the pleading standard for actual malice, not on a finding about the letter.
What does actual malice mean in a defamation case?
Under New York Times Co. v. Sullivan, a public figure suing for defamation must show the publisher made a false statement knowing it was false or with reckless disregard for whether it was false. In the Eleventh Circuit, a public figure has to allege facts that make that plausible in the complaint itself, before any discovery. A failure to investigate, standing alone, does not meet the standard.
Can Trump file the same lawsuit again?
A dismissal with prejudice ends the claims in that court; they cannot be refiled there. A party can ask a federal appeals court to review the ruling, which for the Southern District of Florida is the U.S. Court of Appeals for the Eleventh Circuit. As of November 1, 2026, the docket showed no notice of appeal.
Will Trump have to pay the defendants’ legal fees?
That has not been decided. The defendants asked for fees under Florida’s or New York’s anti-SLAPP law. The judge said the claims lack merit but left the fee question open because the parties had not fully briefed which state’s law applies. The defendants may file a fee motion within 30 days of the October 31, 2026 order.
Is the Trump Wall Street Journal lawsuit a class action?
No. It was an individual defamation lawsuit brought by Donald Trump. There is no class, no settlement and nothing for members of the public to claim.
Sources
• Trump v. Dow Jones & Company, Inc., No. 1:25-cv-23232 (S.D. Fla.) — docket on CourtListener, including the October 31, 2026 order (ECF 80)• Complaint and Demand for Jury Trial (ECF 1, filed July 18, 2025)
• Order on the first motion to dismiss (ECF 59, April 13, 2026)
• First Amended Complaint (ECF 67, filed May 27, 2026)
• Defendants’ motion to dismiss the amended complaint (ECF 68, filed June 10, 2026)
