# Donald Middlebrooks **Donald M. Middlebrooks** (b. December 31, 1946, Orlando, Florida) is a U.S. District Judge for the Southern District of Florida. Nominated by President [[Bill Clinton]] on January 7, 1997 and confirmed by the Senate on May 23, 1997, he received his commission on May 27, 1997 and has sat on that court since. He matters to this knowledge base for one reason: he is the judge who wrote the most explicit judicial finding on record that [[Donald Trump]] uses civil litigation itself as a weapon, and who attached a price to it. ## Background - B.S. in business administration, University of Florida (1968); J.D., University of Florida Levin College of Law (1972), where he was student government president. - Private practice in Orlando, 1973–1974. - Assistant general counsel, then general counsel, to Florida Governor Reubin Askew, 1974–1977. - Roughly two decades in private practice in West Palm Beach before taking the bench. ## Trump v. Clinton On September 8, 2022, Middlebrooks dismissed the amended complaint in [[Trump v. Clinton]] in its entirety, holding the RICO claims time-barred and independently meritless and writing that "the claims presented in the Amended Complaint are not warranted under existing law." On January 19, 2023 he went further, imposing **$937,989.39** in fees and costs on Trump, his lead attorney [[Alina Habba]], and her firm, jointly and severally, under the court's inherent authority. The order is the source of the lines most often quoted against Trump's litigation strategy: > [!quote] "This case should never have been brought. Its inadequacy as a legal claim was evident from the start. No reasonable lawyer would have filed it." > — Judge Donald M. Middlebrooks, sanctions order, *Trump v. Clinton*, S.D. Fla., January 19, 2023 The same order found that "Mr. Trump's deliberate use of a frivolous lawsuit for an improper purpose constitutes bad faith," and described him as "the mastermind of strategic abuse of the judicial process." A separate Rule 11 order had already penalized Trump's attorneys $50,000 plus $16,274.23 in one defendant's fees. The Eleventh Circuit affirmed both sanctions orders on November 26, 2025, in an opinion by Chief Judge William Pryor finding that Trump and his attorneys "committed sanctionable conduct and forfeited their procedural objections." Trump petitioned the Supreme Court on October 9, 2026, asking it to vacate that ruling — a petition that asks, in substance, whether a sitting president and his lawyers can be sanctioned at all. ## Other notable rulings - *Electronic Frontier Foundation v. Shipping & Transit* (2016) — dismissed claims against a serial patent plaintiff. ## See Also - [[Trump v. Clinton]] - [[Alina Habba]] - [[Lawfare]] - [[Elite Impunity]]