Giuliani Defamed Ruby Freeman and Shaye Moss

A federal court has ruled, now the question is one of damages.

“Trump and Rudy” by The White House is in the Public Domain, CC0

Via the NYT: Giuliani Is Liable for Defaming Georgia Election Workers, Judge Says.

A federal judge ruled on Wednesday that Rudolph W. Giuliani was liable for defaming two Georgia election workers by repeatedly declaring that they had mishandled ballots while counting votes in Atlanta during the 2020 election.

The ruling by the judge, Beryl A. Howell in Federal District Court in Washington, means that the defamation case against Mr. Giuliani, a central figure in former President Donald J. Trump’s efforts to remain in power after his election loss, can proceed to trial on the narrow question of how much, if any, damages he will have to pay the plaintiffs in the case.


Judge Howell’s decision came a little more than a month after Mr. Giuliani conceded in two stipulations in the case that he had made false statements when he accused the election workers, Ruby Freeman and Shaye Moss, of manipulating ballots while working at the State Farm Arena for the Fulton County Board of Elections.

It is encouraging that there are at least some consequences for lying to the American people about an election (not to mention what Freeman and Moss had to endure as a result). Hopefully, there will be serious damages awarded.

“I’ve lost my name, and I’ve lost my reputation,” Ms. Freeman testified to the House panel, adding as her voice rose with emotion, “Do you know how it feels to have the president of the United States target you?”

FILED UNDER: Crime, Law and the Courts, US Politics, , , ,
Steven L. Taylor
About Steven L. Taylor
Steven L. Taylor is a Professor of Political Science and a College of Arts and Sciences Dean. His main areas of expertise include parties, elections, and the institutional design of democracies. His most recent book is the co-authored A Different Democracy: American Government in a 31-Country Perspective. He earned his Ph.D. from the University of Texas and his BA from the University of California, Irvine. He has been blogging since 2003 (originally at the now defunct Poliblog). Follow Steven on Twitter


  1. Joe says:

    Unfortunately, this is a “default” judgment – a penalty for not producing required discovery. So, while I appreciate that he is liable, it really doesn’t speak to the substance of his defamatory conduct. But it’s better than a poke in the eye.

  2. @Joe: Indeed.

  3. Jay L Gischer says:

    The thing that astounds me is that Giuliani is a lawyer. Mostly those guys know how to stay within the letter, if not the spirit, of the law. But he has drifted way outside it. Whiskey Tango Foxtrot…

  4. Grumpy realist says:

    @Jay L Gischer: I think in Mr. Giuliani’s case it’s the whiskey indeed…

  5. Michael Reynolds says:

    The Trump story is actually less about Trump than about his cult. If I were writing the Trump story I’d be doing it from the POV of secondary characters because in the end Trump’s just a bag of wind, a con man who got away with it until he didn’t. Interesting certainly, amusing, but not really a tragedy in the Greek slash Shakespearean sense. But Giuliani, now there you’ve got your hubris, your flawed man who is the engine of his own destruction. Trump didn’t so much fall as slither sideways, but Rudy was right up there at the top of the mountain and then down went Humpty, all the way down.

    You could make a good off-Broadway drama out of that, even opera. Hello? Lin Manuel? Or maybe, Matt and Trey?

  6. Barry says:

    @Jay L Gischer: “Trump will see that I am taken care of!”

  7. Beth says:

    The thing that amuses me about all of this is that Republicans want to make suing someone for defamation easier. My guess is that would absolutely bite them in the ass with alacrity.

    @Jay L Gischer:

    Mostly those guys know how to stay within the letter, if not the spirit, of the law.

    Yes, but you are forgetting that all lawyers are freaks and whackjobs. That’s one of the reasons we end up as lawyers. We’re like condensed id wearing people suits. Lol, I once tried to get a defendant to punch me in the face during a hearing. I got real close before the judge shot me down. That would have been so awesome.

  8. Flat Earth Luddite says:

    Moved from Wednesday Forum:


    Rudy is not the first attorney I’ve seen destroy their career and reputation.* Far from it.

    While it’s entertaining (in a third turn at Talladega crash way), there’s a momentary twinge of feeling for the five cars in the pile up. No pity in me for His Orangeness or Rudy, you understand, but for all the hourly peons and serfs in his office who get buried in the wreckage.

    * Most of my sympathy and pity is reserved for the poor schmo who kept telling Rudy and everyone else in power that “no no no, this is calendared, we have to get this out to opposing counsel and the court. ”

    Rudy and his immediate underlings on this case will try to throw that person under the bus. In my experience, the judge never accepts my secretary / assistant / dog ate my homework.

  9. inhumans99 says:

    @Michael Reynolds:

    Yeah, I am still trying to figure out what happened to Rudy to cause him to just absolutely lose his mind. It bears repeating for the jillionth time that plenty of folks once considered Giuliani Americas Mayor.

    However, he has provided so much grist for so many mills, and one of these days a writer is going to write a tome that is 3 times as long as Infinite Jest about the rise and fall of Giuliani, and as you pointed out, maybe we will get a film or two in the future about his rise and fall, or at least a tv mini-series that earns critical acclaim like that OJ Simson trial one that I believe FX produced that won/was nominated for a bunch of awards.

    Giuliani’s life did not have to turn out the way it did, just bizarre what happened to the guy.

    That being said, his actions have consequences and have hurt people, so any judgements that acknowledges that Giuliani hurt folks and needs to be held accountable for his actions and words is okay in my book.

  10. Mister Bluster says:

    Matt and Trey

    (Trigger Warning!)

  11. Pylon says:

    @Joe: It’s a default judgment for sure, but my take is that, given his admissions, and the fact he didn’t produce any documents which would tend to exonerate him (with the judgment as a consequence), it’s close to a decision on the merits.

    And his First Amendment defence? Against a private defamation suit? Come on.

    Interested in the damages portion – we in Canada are pretty limited in damages because of how our courts view punitive damages versus the US. But he’s already on the hook for over $100K in costs, which is a sign of how the court views the conduct.

  12. DK says:

    From Rudy Giuliani Was Always Like This by Jamelle Bouie:

    …if we think of Giuliani as the personification of American resilience in the face of terrorism, then his turn against democracy and the rule of law is bewildering and inexplicable. But if we think of Giuliani as the scowling demagogue who stoked the flames of chauvinism and racial hatred against New York’s first Black mayor for his own gain, then there’s little other than his carefully crafted image in the press that separates the Giuliani of ’92 from the Giuliani of ’23.

    …Giuliani was a fraught and divisive figure. It was the press that labeled him “America’s mayor.” That the epithet continued to stick through the subsequent decade, in the face of scandal and political failure, is only a testament to the persistence of myth in American political coverage, because it is only after internalizing the myth of Giuliani that anyone could be shocked by his steadfast allegiance to Trump.

    …it is easy to see that the two men are of a type. They share the same demagogic instincts, the same boundless resentment, the same authoritarian manner — it is not for nothing that Giuliani reportedly tried to get the 2001 mayoral election canceled so that he could stay in office beyond the limit on his term — and the same willingness to indulge in racism and use it for their own political purposes.

    If there is a question to ask in the wake of Giuliani’s indictment, it isn’t What happened to Rudy? but rather, why was it so hard for so many people to see the truth of who, and what, he always was?

  13. OzarkHillbilly says:

    @Joe: On the other hand, He did admit “that he had made false statements when he accused the election workers…of manipulating ballots,”

  14. Grumpy realist says:

    @OzarkHillbilly: Mr. Giuliani tried to walk back from his earlier admission, saying that he had only said that because he was trying to speed up the process, but the judge wasn’t having any of it.

    No backsies, everyone. You’d think a lawyer would know this. This is almost as funny as the “ChatGPT made up my homework” case.

  15. dazedandconfused says:

    The best answer to the question of what happened to Rudy is perhaps the guy who mentioned “He is drunk all the time”, Michael Cohen, backed up by Jason Miller who also said something to the same effect.

    Seems he has other suits from Dominion and an ex-employee pending. He might as well let the election workers clean him out, empty pockets would effectively end the two pending suits leaving only a criminal prosecution to worry about. As Chesty Puller would say “This simplifies the problem.”

    ETTD, slowly sometimes…always painfully.

  16. Gustopher says:


    Yeah, I am still trying to figure out what happened to Rudy to cause him to just absolutely lose his mind. It bears repeating for the jillionth time that plenty of folks once considered Giuliani Americas Mayor.

    He was always a freak. He happened to be mayor when 9/11 happened, and people thought he looked determined.

    DK has mentioned how he got to be mayor, so I’ll skip that.

    Giuliani is directly responsible for much of the chaos and harm to first responders on 9/11. He had overruled his hand-picked commission that was deciding where to put the cities emergency response coordination center — they selected a location in Brooklyn, Giuliani put it literally in the World Trade Center. The commission had explicitly rejected that alternative because of the risk of terrorism (WTC had been bombed a few years before that, so it wasn’t even just speculation)

    There was also a failure to upgrade radios for first responders. It’s long and complicated and seems to involve wanting to assign city contracts to his friends. This resulted in first responders not getting the evacuation order shortly before the towers collapsed. They weren’t just heroes going into a collapsing building working to get everyone out with no regard to their own safety, they were also people who didn’t receive warnings of a near imminent collapse.

    In a dramatic retelling of his life, he’s basically the mayor from Jaws (inexplicably still mayor in Jaws 2).

    Except the mayor from Jaws never held a press conference to announce that he and his wife were divorcing without letting his wife know ahead of time. Or get his first marriage annulled after “discovering” that he married his cousin. Or used his talk show to repeatedly rant about ferret owners as diseased people who love weasels. Or helped stoke a racist police riot against the previous mayor and then claim that he couldn’t hear the racist epitaphs or see the overturned cars.

    There may be a story there, but I’m not sure it’s the story @Michael Reynolds expects.

    ETA: I was a little surprised by how much more I enjoyed Rudy’s mugshot than Trump’s. I’ve waited decades for that mugshot.

    ETA2: The 9/11 Truthers basically made any questioning of the right wing narrative of 9/11 sound like a conspiracy theory. I hate them and their “jet fuel doesn’t burn that hot”/“Bush planned it” lies. They effectively propped up Giuliani by mixing their nonsense into every criticism.

  17. just nutha says:

    @Barry: All depends on what “take care of” means, eh?

  18. Kathy says:


    In the past, up to the 2008 campaign season at least, Rudy was capable of acting sane and reasonable. Today he looks like past Rudy’s creepy, drunk uncle.

    On the 9/11 truthers, I wonder how they think metallurgy and in particular steel making, has worked ever since the iron age over 2,000 years ago.

  19. wr says:

    @inhumans99: “It bears repeating for the jillionth time that plenty of folks once considered Giuliani Americas Mayor.”

    Yes, but at the same time Joe Arpaio was called “America’s Sheriff.”

    Maybe that’s just a nomenclature you want to avoid…

  20. DK says:


    In the past, up to the 2008 campaign season at least, Rudy was capable of acting sane and reasonable. Today he looks like past Rudy’s creepy, drunk uncle.

    Same career trajectory as Marlon Brando, another great New York actor.

  21. inhumans99 says:


    “Maybe that’s just a nomenclature you want to avoid…” It sure seems like it, lol. This thread has been eye-opening on how scummy Giuliani is.

  22. just nutha says:

    @wr: Or maybe it’s a reflection of how “Americans” (conservatives?) see themselves?

  23. Kathy says:


    I don’t recall such appellation applied to Crazy Joe.

    But in the 1970s, no less an authority than NFL Films*, anointed the Dallas Cowboys “America’s Team.” So, yeah, it’s been problematic for a long time.

    *They are the world’s foremost authority on Football Follies.

  24. Gustopher says:


    In the past, up to the 2008 campaign season at least, Rudy was capable of acting sane and reasonable.

    In 2008 he had stylists. They made sure his hair was neat, his suits fit, and he was shaved and wearing makeup.

  25. Liberal Capitalist says:

    @Michael Reynolds:

    Michael – When I read your post, I could imagine your Trump story much as Chauncey Gardiner. (Being There w/ Peter Sellers).

    But in this case Chance (Chauncey Gardiner) is not quiet, but a completely empty-headed windbag named Trump.

    People believe in Trump because there is nothing there… he strictly becomes a reflection of everyone’s flaws around him. And Trump loved those who would feed his most base instinctual hungers.

    Guiliani saw him as a way to wealth and fame and as a result his once good name is now infamous.

    Those that hovered around him were able to speak with Trump, because Trump has no real knowledge, opinion, or morality of his own. They pour into him like an empty vessel… and he would suck it all in, especially if they fed his ego in doing so.

    We see this in the way Trump speaks: Catchphrases of ideas from others somehow glue together in his halting speech. His received applause and adulation are much the same as a young child reciting their ABC’s and getting nearly much of it correct.

    Trump parroting these items back validated the vanity of those around him, and the cycle continued… to the point of his believing that he did not need to give up the presidency when he lost. If he just wouldn’t leave, it would be OK.

    “We were getting ready to win this election. Frankly, we did win this election,”

    This is his summation of all of those around him, those who attempted to build their fortunes on a hollow shell… who are now surprised that Trump has abandoned them to their fate.

    Quite the Greek tragedy… and it would be entertaining if he didn’t take 35% of the country down with him.

    A disaster when America could least afford one.

  26. CSK says:

    @Liberal Capitalist:

    For a stubborn man, Trump is remarkably easily led. Just preface whatever you want him to do with some outrageous flattery. Tell him he’s brainy, handsome, the world’s most successful businessman, whatever, and he’s your.

    Putin knew this years ago. Back in 2015 or 2016 he made a comment that Trump was smart, and Trump was his forever after.

  27. a country lawyer says:

    @Joe: The default judgment will contain language such as “All allegations of the plaintiff are deemed admitted.” So Giuliani will forever unable to deny the allegations of the plaintiffs. Also, at the damage hearing the plaintiffs will be able to present in excruciating detail Giuliana’s conduct and the effects on the plaintiffs.

  28. Paul L. says:

    Don’t care what Rudy said. Still waiting to see the surveillance video and chain of custody for the ballots for the box.

    OTB: You have no standing to see that evidence.
    Me: Ok I don’t have to believe Ruby Freeman and Shaye Moss just because it is unpatriotic to question US elections unless you are a Democrat.

    I believe most Federal judges are rubber-stamping lackeys and lapdogs for the DOJ. For all of Judge Sullivan scolding, he let the DOJ walk away Scot free from Ted Stevens misconduct. Debunk that with Rule of Law.

  29. Grumpy realist says:

    @Paul L.: you can believe whatever your little heart desires. That still doesn’t give you standing or buttress your argument.

    The only thing you’ve done is made it obvious you don’t care about what actually happened and will totally ignore any evidence that doesn’t support whatever whack job theory is in your brain.

    Your lack of intellectual integrity is not our problem to solve. It’s yours.