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Follow-On Libel Case Stemming from President Trump's 2023 N.Y. Civil Fraud Trial Thrown Out

Eugene Volokh | 6.29.2026 8:01 AM

From Friday's opinion of the U.S. Court of Appeals for the Seventh Circuit in Fredin v. Klasfeld (the opinion doesn't name the participating judges):

Brock Fredin, a social media commentator, appeals the dismissal of his diversity action alleging that a journalist … defamed him by reporting on his well-documented history of harassing women and comparing that conduct to his recent criticism of a judicial law clerk in a high-profile legal proceeding….

Fredin … operates an X (formerly known as Twitter) account in which he criticized Allison Greenfield, the law clerk of the state-court judge presiding over a civil fraud case brought by the State of New York against President Donald Trump and others. Fredin accused Greenfield of violating ethics rules, being politically biased against President Trump, and leaking inside information about the trial to reporters. Fredin rose to prominence after President Trump reposted Fredin's criticism on social media and himself criticized Greenfield.

Soon thereafter, a reporter named Adam Klasfeld, who was covering the fraud case, wrote an article in an online publication called The Messenger that exposed Fredin's history of harassing women—all well-documented through court records of restraining orders and criminal charges against Fredin. Klasfeld reported that Fredin had harassed multiple women by creating websites in their names, emailing their employers and colleagues with accusations of criminal conduct, and filing complaints with their professional organizations.

We will later examine the specific statements, but for now it suffices to say that Klasfeld made clear he was relying on court records. Klasfeld, for instance, repeatedly qualified the accusations against Fredin with phrases like "a court found," "court records show," and "[the judge] wrote." Klasfeld compared Fredin's past harassment of these women to........

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