Melania Trump has expanded her legal battle with author Michael Wolff by asking a federal judge to allow sanctions against his legal team, escalating a dispute that began after Wolff sought court protection against a threatened $1 billion defamation lawsuit tied to his public comments about Jeffrey Epstein and the Trump family.

The latest development unfolded in the U.S. District Court for the Southern District of New York, where attorneys representing the first lady confirmed they intend to file a formal sanctions motion by July 20. The request follows the dismissal of Wolff's anti-SLAPP lawsuit in May and shifts the legal fight from the underlying defamation dispute to whether Wolff's attorneys improperly brought the earlier case.

According to court filings, Melania Trump's lawyers argue that Wolff's lawsuit contained "factual misrepresentations, frivolous legal arguments and bad-faith conduct." They further contended that "Plaintiff's misconduct, and that of his counsel, warrants sanctions," adding that any penalty "should be sufficient to deter repetition and to compensate Mrs Trump for the costs imposed by their misconduct."

The sanctions request stems from Wolff's October 2025 anti-SLAPP action, which was filed after Melania Trump's legal team threatened a $1 billion defamation lawsuit over his comments linking her to Jeffrey Epstein. District Judge Mary Kay Vyskocil later dismissed the anti-SLAPP complaint, ruling that Wolff lacked standing because the first lady had not actually filed the threatened defamation lawsuit. Wolff has appealed that ruling.

At this week's hearing in Manhattan, Judge Mary Kay Vyskocil questioned whether extending the litigation served either side's interests. "I wonder if it's in the interest of the parties to continue litigating in this court," she told Melania Trump's attorneys, noting that "the case is now closed."

The judge also emphasized the legal standard governing Rule 11 sanctions, cautioning that such motions face a demanding evidentiary threshold. She said Melania Trump's legal team would need "clear evidence" that Wolff's lawsuit was frivolous and filed in bad faith, adding that sanctions motions "place a very high burden on the moving party."

Vyskocil further observed: "I think sometimes people get so caught up in the fervor of the moment that they don't really stop and think about the cost-benefit analysis of motions that are contemplated and the burden you put a court to." Nevertheless, she acknowledged that "I cannot stop a party from filing a motion that it believes in good faith is warranted, except in very rare circumstances that aren't present in this case."

Wolff has sharply criticized the sanctions effort. Speaking on his podcast Inside Trump's Head, which he co-hosts with Joanna Coles, he argued that the move represents an attempt to intimidate both him and his attorneys.

"Essentially, they are moving to sanction my lawyers for doing nothing more than bringing the lawsuit against Melania Trump," Wolff said. "So this is preposterous on its face."

He also characterized the legal strategy as part of what he described as "another... kind of thing that comes with all of Trump-style... litigation, which is you do everything, no matter how... sordid and not respectable... and bound to be thrown out of court, you do this stuff to cost your opponents more money and to cause delay."

Wolff additionally claimed he learned about the sanctions strategy through an accidental text message allegedly sent by President Donald Trump's attorney, Boris Epshteyn. According to Wolff, the January message read: "Hey team, what's our timing on the Section 11 filing?" Wolff said the message was mistakenly sent to him because Epshteyn had previously communicated with him off the record.

"I was not part of the team," Wolff said on the podcast after co-host Joanna Coles joked about the mistaken message. Wolff argued the text suggested the litigation strategy "was being coordinated at the highest levels of Trump law." Neither Epshteyn nor Melania Trump's legal team has publicly responded to that specific allegation.

The legal dispute centers on Wolff's repeated public comments concerning Jeffrey Epstein and the Trump family. In public statements and court filings, Wolff has maintained that he never alleged Melania Trump was involved in Epstein's criminal conduct. However, he has continued to defend statements asserting that she "plays no small part" in "the Epstein story" and has stood by broader claims regarding Donald Trump's past relationship with Epstein.

Melania Trump has repeatedly denied those allegations. In a recorded statement released in April, she declared: "the lies linking me with the disgraceful Jeffrey Epstein need to end today."