{"slug":"alina-habba-trump-v-clinton-sanctions-2023","title":"Court Sanctions Habba, Jointly With Trump, $937,989 for Bad-Faith Lawsuit Against Clinton (2023)","date":"2023-01-19","lastUpdated":"2026-10-10","description":"On January 19, 2023, a federal judge in the Southern District of Florida ordered Donald Trump, his lawyer Alina Habba and her firm, Habba Madaio & Associates, to pay $937,989.39 in the defendants' fees and costs, jointly and severally, finding that Trump's racketeering lawsuit against Hillary Clinton and others was brought in bad faith. The court had separately sanctioned Habba and Trump's other lawyers under Rule 11. The Eleventh Circuit affirmed both sanctions orders on November 26, 2025.","summary":"Judge Donald Middlebrooks dismissed Trump's 2022 lawsuit against Clinton and dozens of others, then sanctioned his lawyers under Rule 11 for allegations he found knowingly false or reckless, and sanctioned Trump, Habba and her firm under the court's inherent authority, citing shotgun pleadings, knowingly false factual allegations and frivolous legal theories as evidence of bad faith. The Eleventh Circuit held that Trump and his attorneys committed sanctionable conduct and affirmed.","category":"rule-of-law","severity":"pre-office","ongoing":false,"sources":[{"url":"https://www.govinfo.gov/content/pkg/USCOURTS-ca11-23-10387/pdf/USCOURTS-ca11-23-10387-0.pdf","title":"Trump v. Clinton, Nos. 22-13410, 22-14099, 23-10387, 23-13177 (11th Cir. Nov. 26, 2025), opinion of the court","publisher":"U.S. Court of Appeals for the Eleventh Circuit (via GovInfo)"},{"url":"https://www.newsweek.com/alina-habba-trump-clinton-lawsuits-1775270","title":"Alina Habba Pays the Price for Cozying Up to Donald Trump","publisher":"Newsweek"},{"url":"https://clearinghouse.net/doc/168667/","title":"Trump v. Clinton, No. 2:22-cv-14102 (S.D. Fla.), Order on Motion for Sanctions (ECF No. 302, Jan. 19, 2023), 653 F. Supp. 3d 1198","publisher":"Civil Rights Litigation Clearinghouse (University of Michigan Law School)"},{"url":"https://www.jurist.org/news/2023/01/federal-judge-sanctions-trump-nearly-1m-over-political-litigation-claims/","title":"Federal judge hands Trump nearly $1M in sanctions over political litigation claims","publisher":"JURIST"}],"draft":false,"status":"published","tags":["sanctions","frivolous-litigation","pre-office"],"relatedEntries":[],"timeline":[{"date":"2023-01-19","title":"Inherent-authority sanctions","summary":"Judge Middlebrooks orders Trump, Habba and Habba Madaio & Associates to pay $937,989.39, jointly and severally."},{"date":"2025-11-26","title":"Eleventh Circuit affirms","summary":"The Eleventh Circuit affirms both sanctions orders and the dismissal (except as to one defendant over which the court lacked jurisdiction)."}],"custom":{"posture":"documented","structuredPerpetrators":[{"name":"Alina Habba","role":"Counsel for Donald Trump; partner, Habba Madaio & Associates","institution":"Habba Madaio & Associates"}],"updateLog":[{"date":"2026-10-10","summary":"Added for the Before Office record. Habba became Counselor to the President on January 20, 2025."}],"keyPoints":["In 2022, between his terms, Trump sued Hillary Clinton and dozens of others, alleging racketeering and Florida-law claims; Habba was among four attorneys who signed the amended complaint","The district court dismissed the amended complaint, finding it 'foreclosed by existing precedent', implausible, and a 'quintessential shotgun pleading'","On defendant Charles Dolan's motion, the court sanctioned Trump's attorneys under Rule 11, finding many allegations against Dolan 'knowingly false or made in reckless disregard for the truth', and ordered a $50,000 penalty plus $16,274.23 in fees, citing among other things Habba's post-dismissal Fox News appearance promoting the theory of the case","On the other defendants' motion, the court sanctioned Trump, Habba and her firm under its inherent authority, jointly and severally, for $937,989.39 in fees and costs","On November 26, 2025, the Eleventh Circuit held that 'Trump and his attorneys committed sanctionable conduct and forfeited their procedural objections' and affirmed both sanctions orders"],"verificationStatus":"cross-referenced","postureNote":"Court sanctions under the district court's inherent authority (joint and several, $937,989.39) and under Rule 11 ($50,000 plus $16,274.23 against Trump's attorneys); both affirmed by the Eleventh Circuit on 2025-11-26.","subjects":["alina-habba"],"legalStatus":"civil-liability"}}