Judge Finds No ‘Actual Malice’ in Defamation Case

Miami-based US District Judge Darrin Gayles ruled on Monday that Trump did not meet the “actual malice” standard that public figures must satisfy in defamation cases, according to the source.

The standard requires that public figures prove not only that a public statement about them was false, but also that the media outlet or person who made the statement acted with reckless disregard for the truth or should have known that it was false, according to the source.

“This complaint comes nowhere close to this standard,” Gayles wrote — “Quite the opposite,” the judge said, according to the source.

Judge Notes WSJ Reached Out to Trump for Comment

The judge noted that reporters from the Wall Street Journal (WSJ) reached out to Trump for comment beforehand and printed his denial. That allowed readers to decide for themselves what to conclude, cutting against Trump’s assertion that the newspaper acted with actual malice, the judge said, according to the source.

Gayles said Trump could file an amended version of the lawsuit by April 27, according to the source.

In his lawsuit, Trump called a birthday greeting that he allegedly sent to Epstein, a convicted sex offender, a “fake.” The former US president sought $10bn for what he called damage to his reputation, according to the source.

WSJ Defended Accuracy of Epstein Report

News Corp’s Dow Jones & Company, the WSJ’s parent company, defended the accuracy of its July 17, 2025 article, according to the source.

Trump filed the lawsuit after promising to sue the paper almost immediately after it put a new spotlight on his well-documented relationship with Epstein by publishing an article that described a sexually suggestive letter that the newspaper said bore Trump’s signature and was included in a 2003 album compiled for Epstein’s 50th birthday, according to the source.

The letter was subsequently released publicly by the US Congress, which subpoenaed the records from Epstein’s estate, according to the source.

The ruling marks yet another blow in the Trump administration’s efforts to manage fallout over its release of the Epstein files and the former president’s attempts to use the legal system to curb reporting that he finds critical of him, according to the source.

The White House didn’t immediately respond to a request by AP for comment, according to the source.

US District Judge Darrin Gayles said Trump came “nowhere close” to showing the WSJ acted with actual malice towards him, which is the threshold for defamation cases in the US, according to the source.

The case was dismissed without prejudice, though Trump will be allowed to file a new, amended lawsuit; he has until 27 April to do so, according to the source.

Trump’s lawyer said the former president will “continue to hold accountable those who traffic in Fake News to mislead the American People,” according to the source.

The standard for “actual malice” in defamation cases is that defendants must prove that a public statement was both false, and that the news organisation or individual who made the statement knew or should have known that it was false or acted in reckless disregard of its falsity, according to the source.

In his ruling, Gayles said he had to dismiss the complaint because Trump had “not plausibly alleged that the Defendants published the Article with actual malice,” according to the source.

The WSJ, owned by Murdoch’s company News Corp., published exclusive reporting over the summer tying Trump and Epstein together through the birthday book, according to the source.

Weeks later, Democratic lawmakers published an image of the birthday note on social media, ahead of the release of other documents related to Epstein, according to the source.

The newspaper did not publish an image of the note at the time but the details of its written description matched the picture that was released by lawmakers, according to the source.

Trump said the message was “a fake thing” and denied writing it, according to the source.