Court Upholds $1M Sanctions Against Trump and Alina Habba for ‘Frivolous’ Lawsuit Against Clinton and Comey

AP Photo/David Goldman

Yet again, President Donald Trump’s social media bluster has not translated to a legal victory, with an appellate court upholding the dismissal of his lawsuit against former Secretary of State Hillary Clinton, former FBI director James Comey, and others — plus nearly $1 million in sanctions against the president and his attorneys.

In 2022, Trump sued dozens of defendants, including Clinton, Comey, the Democratic National Committee, the Perkins Coie law firm, alleging they had “maliciously conspired to weave a false narrative” that he was colluding with Russia in the lead up to the 2016 presidential election, claiming the defendants had violated Florida law and the Racketeering Influenced and Corrupt Organizations Act (RICO) and seeking $72 million in damages.

The complaint was dismissed with prejudice in Jan. 2023 by Judge Donald Middlebrooks of the U.S. District Court for the Southern District of Florida, an appointee of President Bill Clinton, in a scathing 46-page order that excoriated the president and Alina Habba, his lead counsel, for bringing “a lawsuit that should never have been filed, which was completely frivolous, both factually and legally, and which was brought in bad faith for an improper purpose.”

“This case should never have been brought,” wrote Middlebrooks. “Its inadequacy as a legal claim was evident from the start. No reasonable lawyer would have filed it. Intended for a political purpose, none of the counts of the amended complaint stated a cognizable legal claim.”

The judge blasted Trump specifically as “a prolific and sophisticated litigant who is repeatedly using the courts to seek revenge on political adversaries” and “the mastermind of strategic abuse of the judicial process.”

Middlebrooks ordered Trump and Habba to pay $938,000 in sanctions to cover the defendants’ legal expenses, with them jointly and severally liable for the penalty.

Wednesday’s 36-page ruling by a unanimous three-judge panel on the U.S. Court of Appeals for the Eleventh Circuit is similarly harsh in its assessment of Trump’s legal claims.

The president can’t reasonably complain this was a result of “liberal activist judges,” with Chief Judge William Pryor a staunch conservative jurist who met with such vociferous opposition from Senate Democrats that President George W. Bush initially put him on the court with a recess appointment, and Judge Andrew Brasher, a former Federalist Society member appointed by Trump himself, both ruling against Trump and then joined by Biden appointee Judge Embry Kidd for a unanimous decision.

In the opinion, the court affirmed both the dismissal of the complaint and the sanctions, noting that Trump’s complaint was a “shotgun lawsuit,” meaning that it was sloppily drafted, repeated baseless allegations through multiple counts, included vague or immaterial facts, and otherwise “motivated by an improper purpose,” meant to harass or retaliate against a defendant rather than state a cognizable legal claim.

Trump’s claims were either time-barred or otherwise failed to properly state a claim, the court affirmed, bluntly rejecting Trump’s arguments that the four-year statute of limitations for RICO claims should be tolled and noting that the appeal had “fail[ed] to identify a single material fact…previously unknown to them.”

The lawsuit was “frivolous” in “all three ways available” under the Rule 11 of the Federal Rules of Civil Procedure, and the sanctions entered by the district court, Pryor wrote, were based on the evidence of “bad faith” by Trump and Habba, including the “shotgun pleadings, knowingly false factual allegations, and frivolous legal theories,” further noting that this conduct was “willful,” as shown by an appearance Habba made on Fox News after the complaint was dismissed but she “continued to promote the theory of the case.”

The nearly $1 million sanctions was reasonable as well, the court found, because Trump had filed other “frivolous” lawsuits and had a “pattern of misusing the courts,” and the amount was “largely reasonable,” as the legal costs were “substantially discounted” from the total that had been billed, and Trump had been able to make “line-by-line objections to the hours billed and reduced certain attorneys’ hours to account for vague or block billing.”

Trump and Habba did get some relief from the court, with the ruling rejecting the defendants’ motions for appellate sanctions, but upheld the original penalty.

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