Donald Trump sued the IRS for $10 billion.
That sentence sounds like something a man would say after three martinis, two applause lines, and a long conversation with his mirror. But it happened. President Trump, Donald Trump Jr., Eric Trump, and the Trump Organization sued the IRS over the leak of Trump tax information. Then, on May 18, 2026, Trump voluntarily dismissed the lawsuit. The terms of the dismissal were not immediately available, and Judge Kathleen Williams had already set a May 27 hearing to consider whether the case presented a genuine dispute between truly adverse parties.
That should not be the end of it.
Your Honor, set an Order to Show Cause why Rule 11 sanctions should not be imposed against Donald Trump, the other Trump plaintiffs, their attorneys, and any responsible law firm.
Not tomorrow. Not after the next round of cable-news fog. Now.
Because this was not a normal lawsuit. This was Donald Trump v. Donald Trump’s IRS, defended by Donald Trump’s Justice Department, with possible payment from Donald Trump’s Treasury, using money from people who are very much not Donald Trump.
In ordinary litigation, there are two sides. Here, there was Trump at one table, and across the courtroom, the executive branch he controls. That is not adversarial litigation. That is a man arm-wrestling himself and charging admission.
Reuters reported that Judge Williams questioned whether the parties were “truly antagonistic,” and Bloomberg Tax reported that she questioned whether the parties were sufficiently adverse for subject-matter jurisdiction. That is not some law-school parlor game. Federal courts exist to decide real cases and controversies, not staged performances between a President and agencies housed inside his own branch of government.
And then there is the number.
Ten billion dollars.
Not ten million. Not one hundred million. Ten billion. A number so bloated it should have arrived in court with its own cardiologist.
The leak itself was real. Former IRS contractor Charles Littlejohn pleaded guilty and was sentenced to five years in prison for leaking tax information about Trump and others. Nobody has to defend the leak to recognize the separate problem here: the President and his lawyers took a serious privacy issue and inflated it into a $10 billion courthouse spectacle.
That is where California has something to teach the Florida circus.
In Hudson v. Moore Business Forms, Inc., 836 F.2d 1156, 1160–64 (9th Cir. 1987), the Ninth Circuit held that even where some underlying counterclaims were not entirely frivolous, an unsupported damages demand could itself justify Rule 11 sanctions. There, Moore Business Forms filed a counterclaim against former employee Ida Hudson and demanded $200,000 in compensatory damages and $4 million in punitive damages. The Ninth Circuit concluded that the $4.2 million damages claim had no plausible factual or legal basis and was made for the improper purpose of harassing Hudson.
The later Ninth Circuit opinion summarized the holding cleanly: although Moore’s counterclaims were plausible enough not to be sanctionable, the damages claims were “frivolous and brought to harass Hudson,” so sanctions were proper, subject to recalculation based on the frivolous damages demand. Hudson v. Moore Business Forms, Inc., 898 F.2d 684, 686 (9th Cir. 1990).
That is the lesson: a lawyer does not get to staple a cartoon number to a pleading and call it damages.
A damages prayer is not a campaign slogan. It is not a press release. It is not a fundraising graphic. It is a representation to a federal court that the claim has factual and legal support after reasonable inquiry.
Rule 11 says exactly that. It authorizes sanctions against an attorney, law firm, or party responsible for violating the rule. It also permits the court, on its own initiative, to order an attorney, law firm, or party to show cause why specifically described conduct has not violated Rule 11(b). And absent exceptional circumstances, a law firm must be held jointly responsible for a violation committed by its lawyer.
So let us not play the usual Washington game.
This was not merely a client problem. And it was not merely a lawyer problem.
If Trump authorized a lawsuit that used the federal courts for political theater, personal leverage, promotional grievance, or a taxpayer-funded shakedown, then Trump should answer for it. If his lawyers signed and advanced a complaint seeking $10 billion without a serious evidentiary basis, then the lawyers should answer for it. If a law firm lent its name and letterhead to the exercise, then the firm should answer for it too.
The rule allows it. The facts call for it. The dignity of the court demands it.
Now, yes, there are limits. Rule 11 does not permit monetary sanctions against a represented party merely for making a frivolous legal contention under Rule 11(b)(2). But that does not give a represented party a golden parachute for improper purpose, unsupported factual claims, or abuse of the judicial process. And it certainly does not mean lawyers can escape responsibility for putting legally and factually unsupported claims in a complaint.
Your Honor, ask them the simple questions:
- Where did the $10 billion figure come from?
- What admissible evidence supported it?
- What legal authority justified it?
- What reasonable prefiling investigation was conducted?
- What made this a real Article III controversy when the plaintiff was the President and the defendants were executive agencies subject to presidential control?
- And perhaps most importantly: was this lawsuit filed to obtain lawful judicial relief, or was it filed to create a headline, a negotiating chip, a grievance narrative, or a public-relations weapon?
Because federal court is not a campaign prop. It is not a publicity booth. It is not a slot machine. It is not a place where powerful men file billion-dollar fantasies, get the headline, and then disappear when the judge reaches for the flashlight.
And voluntary dismissal does not erase the problem.
The Supreme Court made that clear in Cooter & Gell v. Hartmarx Corp., 496 U.S. 384 (1990). A voluntary dismissal does not deprive a district court of jurisdiction to consider Rule 11 sanctions, because the Rule 11 violation is complete when the offending paper is filed, and dismissal does not expunge the violation. Sanctions are collateral to the merits and exist to protect the integrity of the judicial process.
The Supreme Court reinforced the same principle in Willy v. Coastal Corp., 503 U.S. 131 (1992), holding that a court may impose Rule 11 sanctions even where the court is later determined to lack subject-matter jurisdiction. The court’s interest in having its rules obeyed does not vanish just because the underlying case goes away.
So nobody should be allowed to say: “Never mind, Judge, we were just kidding.”
The courthouse is not a toy.
The judicial process should not be played with, toyed with, or used for promotional purposes — not by anyone, and certainly not by lawyers and the President of the United States.
Lawyers are officers of the court. The President swears to take care that the laws be faithfully executed. If those two groups are not held to a higher standard, then there is no higher standard. There is only rank, muscle, money, and the hope that a federal complaint can be used like another microphone.
This is why the court should not close the file quietly.
Your Honor, set the OSC.
Make Trump explain the number. Make the Trump plaintiffs explain the purpose. Make the lawyers explain the legal theory. Make the law firm explain the investigation. Make everyone involved explain why this was not an abuse of process dressed up in a caption.
Because if this case disappears without consequence, the lesson will be obvious. The next powerful litigant will know the recipe: File first. Demand the moon. Generate the headlines. Use the court as scenery. Dismiss when the judge starts asking whether the whole thing is real.
No, Your Honor. Not this time.
Take a lesson from California. In Hudson, the Ninth Circuit said a damages claim can be sanctionable when it lacks a plausible basis and appears designed to harass. That was true for a $4.2 million claim against an unemployed former employee. It should be at least as true for a $10 billion claim filed by a sitting president against agencies within his own executive branch.
The leak may have been real. The grievance may have been real. But the lawsuit still had to be real. And if the $10 billion demand was not supported, if the adversity was manufactured, if the courthouse was used as a promotional stage, then Rule 11 should have consequences.
Order Trump and his attorneys to show cause why they should not be sanctioned. Then, unless they can produce something better than smoke, swagger, and a damages number pulled from the Mar-a-Lago chandelier, sanction them both. Because you can dismiss a case. You cannot dismiss responsibility for filing it.
