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Court Sanctions Habba, Jointly With Trump, $937,989 for Bad-Faith Lawsuit Against Clinton (2023)

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.

Record summary

Grade

Outside the grading scale: Pre-Office Conduct

International crime

Pre-office conduct — outside the official-power scale

Conduct from before office: Donald Trump’s before the June 2015 campaign launch, and an administration official’s before their first appointment or between terms. Scale and definitions

Status
Concluded
Legal status
Civil liability
Before Office
Alina Habba (all before-office records)
Incident date
Record updated
Category
Rule of Law
Legal posture
Documented
Verification
Cross-referenced
Sources
4 cited
Stable ID
alina-habba-trump-v-clinton-sanctions-2023
Posture note
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.
Alleged responsible parties
  • Alina Habba, Counsel for Donald Trump; partner, Habba Madaio & Associates— Habba Madaio & Associates

Key points

  • 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

What happened

In 2022, between his terms of office, Donald Trump filed a lawsuit in the Southern District of Florida against Hillary Clinton and dozens of other defendants, alleging two racketeering claims and three claims under Florida law. Alina Habba and Michael Madaio of Habba Madaio & Associates, with two lawyers from the Ticktin Law Group, represented him. The initial complaint, filed on March 24, 2022, against 28 named defendants, ran to 108 pages and 508 numbered paragraphs; the amended complaint added more than eighty pages and was signed by Habba, Madaio, and two Ticktin lawyers.

The district court dismissed the amended complaint with prejudice. It found the claims "foreclosed by existing precedent," implausible, and a "quintessential shotgun pleading," and found that the complaint "misrepresent[ed]" its sources.

  • Rule 11 sanctions: on defendant Charles Dolan's motion, the court found many allegations against him "knowingly false or made in reckless disregard for the truth," that the legal theory lacked "any chance of success," and that the suit had an improper purpose. It ordered Trump's attorneys to pay a $50,000 penalty plus $16,274.23 of Dolan's fees, finding their conduct "willful."
  • Inherent-authority sanctions (January 19, 2023): on the other defendants' joint motion, the court described the shotgun pleadings, knowingly false factual allegations and frivolous legal theories as evidence of bad faith, and held Trump, Habba and her firm jointly and severally liable for $937,989.39 in fees and costs. The order (ECF No. 302) is dated January 19, 2023; Newsweek described it as a 46-page ruling.
  • Appeal: on November 26, 2025, the Eleventh Circuit (Chief Judge William Pryor, Judges Brasher and Kidd) held that "Trump and his attorneys committed sanctionable conduct and forfeited their procedural objections" and affirmed both sanctions orders. It declined to impose further appellate sanctions.

Sources

  • Trump v. Clinton, Nos. 22-13410, 22-14099, 23-10387, 23-13177, opinion of the court (11th Cir. Nov. 26, 2025), via GovInfo.
  • Ewan Palmer, "Alina Habba Pays the Price for Cozying Up to Donald Trump," Newsweek, January 20, 2023.
  • Trump v. Clinton, No. 2:22-cv-14102 (S.D. Fla.), Order on Motion for Sanctions, ECF No. 302 (January 19, 2023), docket listing via the Civil Rights Litigation Clearinghouse.
  • Madeline Bruce, "Federal judge hands Trump nearly $1M in sanctions over political litigation claims," JURIST, January 20, 2023.

Update log

  1. Added for the Before Office record. Habba became Counselor to the President on January 20, 2025.

Sequence of events

  1. Inherent-authority sanctions

    Judge Middlebrooks orders Trump, Habba and Habba Madaio & Associates to pay $937,989.39, jointly and severally.

  2. Eleventh Circuit affirms

    The Eleventh Circuit affirms both sanctions orders and the dismissal (except as to one defendant over which the court lacked jurisdiction).

Sources

  1. Trump v. Clinton, Nos. 22-13410, 22-14099, 23-10387, 23-13177 (11th Cir. Nov. 26, 2025), opinion of the court — U.S. Court of Appeals for the Eleventh Circuit (via GovInfo)
  2. Alina Habba Pays the Price for Cozying Up to Donald Trump — Newsweek
  3. 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 — Civil Rights Litigation Clearinghouse (University of Michigan Law School)
  4. Federal judge hands Trump nearly $1M in sanctions over political litigation claims — JURIST

How this record was published

Manually curated This entry was added directly and does not carry an automated audit trail.

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