US District Judge Darrin Gayles ruled in Miami on Saturday that Trump’s amended complaint failed to establish that the newspaper and other defendants acted with actual malice. He dismissed the case with prejudice, preventing the president from filing the same claims again in the district court.
The ruling followed an earlier dismissal in April, when Gayles allowed Trump to revise his allegations. The president submitted an amended complaint in May, but the judge found that it still failed to meet the legal threshold governing defamation actions brought by public figures.
“Grasping at straws, the Amended Complaint attempts to manufacture flaws with the investigation,” Gayles wrote, referring to the newspaper’s work before publishing its account of a letter allegedly bearing Trump’s signature.
The judge described the newspaper’s investigation as thoughtful and detailed, highlighting efforts by its journalists to seek responses from Trump and other people before publication. He rejected the contention that the newspaper should have abandoned its story simply because the president disputed the document’s authenticity.
“That is not what the actual malice standard requires and runs afoul of the First Amendment,” Gayles wrote.
Trump’s legal team said it would appeal the decision. A spokesperson maintained that the president would continue pursuing the newspaper and other defendants over what the team characterised as false and damaging coverage. Dow Jones, the Journal’s publisher, welcomed the ruling and stood by its reporting.
The dispute arose from a July 2025 article describing a sexually suggestive letter that the newspaper said appeared in an album assembled for Epstein’s 50th birthday in 2003. The document included typewritten words framed by an outline resembling a naked woman and a signature appearing to read “Donald”.
Trump has denied writing, drawing or signing the letter, describing the newspaper’s account as false and defamatory. His lawsuit accused the defendants of knowingly or recklessly publishing inaccurate statements that caused substantial financial and reputational damage.
The defendants included Dow Jones, News Corp, Murdoch, News Corp chief executive Robert Thomson and two journalists involved in the article. Trump sought damages of at least $10 billion in the amended proceedings.
Gayles concluded that the complaint offered insufficient factual grounds to infer that the defendants knew their reporting was false or recklessly disregarded evidence of falsity. He said several allegations were vague, conclusory or inconsistent with what the published article actually stated.
The ruling stressed that the Journal had expressly included Trump’s denial. That detail undermined the argument that its journalists deliberately concealed information contradicting their account, according to the court.
The judge relied on the US Supreme Court’s 1964 decision in New York Times Co. v Sullivan, which requires public officials pursuing defamation claims to establish actual malice. The standard concerns knowledge of falsity or reckless disregard for truth, rather than hostility towards the person covered.
The distinction was central to the dispute because Trump argued that his unequivocal denial should have alerted the journalists to the alleged falsity of the material. Gayles found that a denial alone did not establish the necessary state of mind. The court examined the allegations about the investigation, the reporting process and the information available to the defendants before the article appeared.
The court’s decision did not determine whether Trump created the disputed letter. Instead, it addressed whether the allegations in his complaint were legally sufficient to sustain a defamation action against the publisher and the other defendants.
The dismissal also leaves the president with the option of seeking appellate review, notwithstanding the prohibition on refiling the same complaint before Gayles. Any appeal would require a higher court to examine whether the district judge correctly applied the governing legal standard.
The letter was described as part of a birthday collection organised by Ghislaine Maxwell, Epstein’s longtime associate. Its reported contents included a message wishing Epstein a happy birthday and referring to secrets. Trump has consistently rejected the suggestion that he contributed to the collection.
Epstein, a convicted sex offender, died by suicide in federal custody in New York in August 2019 while awaiting trial on sex-trafficking charges. Authorities have not accused Trump of participating in Epstein’s criminal offences.
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