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S.D. Fla.October 31, 2026Motion to Dismiss Granted in Part (Complaint Dismissed Without Prejudice); Request for Judicial Notice Granted in Part⭐ Notable

Trump v. Dow Jones & Co., Inc.

Case No. 1:25-cv-23232

President Trump sued Dow Jones and affiliated defendants for defamation per se and per quod over a Wall Street Journal article describing a bawdy birthday letter bearing his signature in Jeffrey Epstein's 50th-birthday album. Applying Florida defamation law, the court dismissed the complaint without prejudice for failure to plausibly plead actual malice under Twombly/Iqbal, and dismissed the per quod count separately for failure to plead special damages. The court also refused to incorporate by reference or judicially notice the congressionally-released Birthday Book and Produced Letter because their authenticity was disputed.

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Key facts

  • President Trump sued Dow Jones & Co. and affiliated defendants for defamation over a Wall Street Journal article describing a birthday letter bearing his signature that appeared in Jeffrey Epstein's 50th-birthday album.
  • Trump pleaded defamation per se and per quod, alleging the defendants knew the statements were false, acted with actual malice and ill-will, and caused him special damages.
  • +2 more key facts with a free trial

Why it matters

A high-profile application of Florida defamation pleading rules that practitioners can cite for several reusable propositions: a publisher's pre-publication outreach and inclusion of the subject's denial affirmatively… — full analysis with a trial

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