Rudolph W. Giuliani · defamation · civil litigation · elections · professional discipline
How was Rudy Giuliani found liable to Ruby Freeman and Shaye Moss, and what happened to the $148 million judgment and his law licences?
As of 30 October 2026 the $148 million judgment won by Ruby Freeman and Wandrea' ArShaye Moss is recorded as fully satisfied, by a notice filed on 24 February 2025 after a settlement whose financial terms were not disclosed. Liability was decided by default judgment on 30 August 2023 as a discovery sanction, not by a trial on the merits, and a jury set damages on 15 December 2023. Giuliani's bankruptcy case was dismissed on 12 July 2024. He was disbarred in New York on 2 July 2024 and in the District of Columbia on 26 September 2024.
Last verified 30 October 2026. United States
The record at a glance
| What was alleged? | Freeman and Moss, former Fulton County, Georgia election workers, alleged that Giuliani defamed them by falsely accusing them of election fraud during the 2020 vote count, and brought claims for defamation, intentional infliction of emotional distress and civil conspiracy, seeking punitive damages.1,2 |
|---|---|
| Who made the claim? | Ruby Freeman and Wandrea' ArShaye Moss (civil plaintiffs), 23 December 2021 |
| How did Rudy Giuliani respond? | Giuliani contested the case and stood by his voter fraud claims after the verdict, calling the award absurd and saying he would appeal. In his January 2025 statement on the settlement he said he was satisfied with the result, had kept his New York co-op, Florida condominium and personal belongings, and had agreed with the plaintiffs not to defame each other. In a post on X he described the New York disbarment case as based on an activist complaint.2,3,4 (the subject's position) |
| Was there an official finding? | Liability was entered by default judgment on 30 August 2023 as a sanction for discovery failures, without a trial on liability.1 A jury awarded about $148 million in damages on 15 December 2023.2 Plaintiffs' counsel filed notice on 24 February 2025 that the final judgment had been fully satisfied.5 Giuliani was disbarred in New York on 2 July 2024 and in the District of Columbia on 26 September 2024.3,7 |
| Was liability determined? | Yes, liability was determined. Liable by default judgment entered as a discovery sanction on 30 August 2023, with damages set by a jury on 15 December 2023. The judgment was later recorded as fully satisfied after a January 2025 settlement whose financial terms were described by Giuliani's lawyer as confidential. Giuliani's statement on the settlement said it does not involve an admission of liability or wrongdoing by any of the parties. Separately, two courts disbarred him in professional discipline proceedings.1,2,4,5 |
| What changed later? | As of 30 October 2026 the judgment is recorded as fully satisfied, the bankruptcy is dismissed, and Giuliani remains disbarred in New York and the District of Columbia.3,5,7 |
| When was this checked? | 30 October 2026 |
What was alleged?
Freeman and Moss, former Fulton County, Georgia election workers, alleged that Giuliani defamed them by falsely accusing them of election fraud during the 2020 vote count, and brought claims for defamation, intentional infliction of emotional distress and civil conspiracy, seeking punitive damages.1,2
Made by Ruby Freeman and Wandrea' ArShaye Moss (civil plaintiffs) on 23 December 2021.
What did Rudy Giuliani say?
Giuliani contested the case and stood by his voter fraud claims after the verdict, calling the award absurd and saying he would appeal. In his January 2025 statement on the settlement he said he was satisfied with the result, had kept his New York co-op, Florida condominium and personal belongings, and had agreed with the plaintiffs not to defame each other. In a post on X he described the New York disbarment case as based on an activist complaint.2,3,4
"The absurdity of the number merely underscores the absurdity of the entire proceeding."
Rudy Giuliani, outside court (reported by CBS News), 15 December 2023. This is the subject's own account, not a finding.
What do independent records show?
Order, Freeman v. Giuliani, Civil Action No. 21-3354 (BAH)
US District Court for the District of Columbia, Judge Beryl A. Howell, 30 August 2023
Granted the plaintiffs' motion for discovery sanctions under Federal Rules of Civil Procedure 37(e)(2)(C) and 37(b)(2)(A)(vi) and directed entry of default judgment against Giuliani on liability for defamation, intentional infliction of emotional distress, civil conspiracy and punitive damages. A separate trial was set on damages.1
Jury verdict on damages
US District Court for the District of Columbia (jury), 15 December 2023
Awarded $16,171,000 to Freeman and $16,998,000 to Moss in compensatory damages for defamation, $20 million each for emotional distress, and $75 million in punitive damages, about $148 million in total. Final judgment was entered on 18 December 2023.2,5
Matter of Giuliani, Case No. 2021-00506
Appellate Division of the New York Supreme Court, First Department, 2 July 2024
Disbarred Giuliani effective immediately. As reported by AP, the court wrote that nothing on the record would permit the conclusion that he lacked knowledge of the falsehood of his statements about the 2020 election.3
Dismissal of Giuliani's Chapter 11 case
US Bankruptcy Court for the Southern District of New York, Judge Sean H. Lane, 12 July 2024
Dismissed the bankruptcy case, citing a lack of transparency, which allowed the judgment creditors to pursue collection.6
Opinion imposing reciprocal discipline, Bar Docket No. 2020-D253
District of Columbia Court of Appeals, 26 September 2024
Disbarred Giuliani as reciprocal discipline matching New York, nunc pro tunc to 9 August 2021.7
Notice of Satisfaction of Judgment, filed by plaintiffs' counsel
US District Court for the District of Columbia, 24 February 2025
States that Giuliani has fully satisfied the Final Judgment entered on 18 December 2023.5,8
What was established?
- Liability was entered by default judgment on 30 August 2023 as a sanction for discovery failures, without a trial on liability.1
- A jury awarded about $148 million in damages on 15 December 2023.2
- Plaintiffs' counsel filed notice on 24 February 2025 that the final judgment had been fully satisfied.5
- Giuliani was disbarred in New York on 2 July 2024 and in the District of Columbia on 26 September 2024.3,7
Distinctions that matter here
- A default judgment establishes liability because of the defendant's litigation conduct. It is not a jury finding on the merits of the claims.
- Satisfaction of a judgment means it has been paid or otherwise discharged. It does not vacate the judgment.
- Disbarment is professional discipline, separate from civil liability.
- A federal pardon covers federal crimes only and does not affect civil judgments.
Was liability determined?
Yes, liability was determined. Liable by default judgment entered as a discovery sanction on 30 August 2023, with damages set by a jury on 15 December 2023. The judgment was later recorded as fully satisfied after a January 2025 settlement whose financial terms were described by Giuliani's lawyer as confidential. Giuliani's statement on the settlement said it does not involve an admission of liability or wrongdoing by any of the parties. Separately, two courts disbarred him in professional discipline proceedings.1,2,4,5
What remains unresolved?
- The amount and source of the payment that satisfied the judgment have not been made public.
What is the current status?
As of 30 October 2026 the judgment is recorded as fully satisfied, the bankruptcy is dismissed, and Giuliani remains disbarred in New York and the District of Columbia.3,5,7
As of 30 October 2026. No next proceeding is scheduled in the records we found.
Timeline
- Freeman and Moss file suit in federal court in Washington.1
- Judge Howell enters default judgment on liability as a discovery sanction.1
- Jury awards about $148 million in damages.2
- Giuliani files for Chapter 11 bankruptcy.6
- New York appellate court disbars Giuliani.3
- Bankruptcy case dismissed.6
- District of Columbia Court of Appeals disbars Giuliani.7
- Settlement announced in the Manhattan collection case before Judge Lewis Liman.4,8
- Notice filed that the judgment has been fully satisfied.5,8
- The Associated Press reports that Ed Martin, the Justice Department's pardon official, announced a presidential pardon covering federal crimes for Giuliani and others involved in efforts to overturn the 2020 election. Giuliani was never federally charged, and AP notes the pardon applies only to federal crimes.9
Sources
- CourtListener RECAP (US District Court for the District of Columbia), Order, Freeman v. Giuliani, Civil Action No. 21-3354 (BAH), ECF No. 93, 30 August 2023 · document record Court, legislation, official register or regulator record
- CBS News, Rudy Giuliani verdict in defamation trial brought by Georgia election workers, 15 December 2023 Independent reporting
- WSLS, Giuliani disbarred in NY as court finds he repeatedly lied about Trump's 2020 election loss (Associated Press), 2 July 2024 Independent reporting
- Courthouse News Service, Rudy Giuliani can keep Florida condo, personal belongings after settling turnover case with election workers, 16 January 2025 Independent reporting
- CourtListener RECAP (US District Court for the District of Columbia), Notice of Satisfaction of Judgment, Freeman v. Giuliani, Civil Action No. 21-3354 (BAH), ECF No. 167, 24 February 2025 · document record Court, legislation, official register or regulator record
- KSAT, Judge throws out Rudy Giuliani's bankruptcy case, says he flouted process with lack of transparency (Associated Press), 12 July 2024 Independent reporting
- District of Columbia Bar, Disciplinary case record, Rudolph W. Giuliani, Docket No. 2020-D253, 26 September 2024 · document record Government, parliamentary or audit document
- KSL, Giuliani has fully satisfied Georgia election workers' $148M judgment, court filing shows (Reuters), 24 February 2025 Independent reporting
- WECT, Trump pardons Rudy Giuliani, others involved in efforts to overturn 2020 election, DOJ attorney says (Associated Press), 10 November 2025 Independent reporting
Revision history
- 30 October 2026: First published after source verification.
Related: Rudolph W. Giuliani, defamation, civil litigation, elections, professional discipline, United States. To submit a document or request a correction, see right of reply.