A federal judge in Miami on Monday dismissed President Donald Trump's $10 billion defamation suit against Dow Jones & Company and Rupert Murdoch, ruling that Trump's complaint did not adequately allege the Wall Street Journal published its Epstein-related reporting with actual malice. Judge Darrin P. Gayles gave Trump until April 27 to file an amended complaint.
The suit, Trump v. Dow Jones and Company Inc., No. 1:25-cv-23232-DPG (S.D. Fla.), challenged a Journal story describing a sexually suggestive letter that the paper said bore Trump's signature and was included in a 2003 album compiled for Jeffrey Epstein's 50th birthday. Trump denied writing the letter and called the story false and defamatory.
Judge Gayles dismissed both counts — defamation per se (Count I) and defamation per quod (Count II). The per quod claim failed independently for Trump's failure to plead special damages. But the central deficiency across both counts was actual malice.
The opinion turned on what the Journal did before it published. The court found that the paper's pre-publication contact with Trump, DOJ officials, and the FBI showed the Journal attempted to investigate the story's claims — undercutting any inference of reckless disregard. The court also held that the articles' inclusion of Trump's own denial made actual malice less plausible, not more. And the opinion made clear that ill will toward Trump, even if shown, is irrelevant to the actual-malice inquiry under New York Times Co. v. Sullivan.
Importantly, Judge Gayles did not resolve the underlying factual disputes. "Whether President Trump was the author of the Letter or Epstein's friend are questions of fact that cannot be determined at this stage," the court wrote. The dismissal was about pleading sufficiency, not the truth of the Journal's account.
The court denied the defendants' motion for anti-SLAPP fees without prejudice.
Dow Jones said it was "pleased" with the ruling and that it "stand[s] behind the reliability, rigor and accuracy of The Wall Street Journal's reporting." Trump characterized the decision as "not a termination" but a "suggested re-filing" and said he would refile on or before the April 27 deadline.