Trump v. Internal Revenue Service

Summary

President Donald Trump, Donald Trump Jr., Eric Trump, and the Trump Organization sued the IRS and Department of the Treasury under 26 U.S.C. Section 7431 over the illegal disclosure of their confidential tax returns by IRS contractor Charles Littlejohn in 2023, seeking at least $10 billion in damages.

The case was dismissed 109 days after filing via a voluntary dismissal, alongside a "settlement agreement" that included a formal U.S. apology and creation of a $1.776 billion "Anti-Weaponization Fund."

On July 13, 2026, the Court found there was never a case or controversy because President Trump controlled both sides of the litigation, imposed Rule 11 and inherent-authority sanctions, and prohibited the parties from citing the settlement agreement in any proceeding, effectively making it unenforceable.

In 2023, the Department of Justice charged IRS contractor Charles Littlejohn with illegally disclosing the confidential tax return information of Donald Trump, his sons Eric and Donald Jr., and the Trump Organization to the New York Times and ProPublica.

Littlejohn pleaded guilty in October 2023 and was sentenced to 60 months incarceration in January 2024.

In every other lawsuit arising from the Littlejohn disclosures, the DOJ vigorously defended the government.

This complaint was filed January 29, 2026 by Donald Trump, Donald Trump Junior, Eric Trump, and the Trump Organization against the IRS and Treasury Department, seeking at least $10 billion.

The DOJ never appeared, never answered, and never filed a single pleading. Eventually the judge appointed an amicus curia to represent the interests of the American People in the proceedings.

On May 18, 2026, the Plaintiffs (Trumps) and Defendants (IRS) executed a settlement agreement that included a U.S. apology, a $1.776 billion Anti-Weaponization Fund, and a Release Order barring future IRS audits of the Trump family. The case was voluntarily dismissed the same day.

Issue

Whether Article III's case-or-controversy requirement was satisfied when the President of the United States sued executive agencies under his direct control who made no attempt to defend the country against the President.

Article III, Section 2

Federal judicial power is restricted to actual cases and controversies between adverse litigants.

**Adverseness** is a constitutional minimum that must be satisfied in every federal case seeking judicial determination. Where one party is the dominus litis -- the master of the suit on both sides -- no case or controversy exists.

Rule 11. Signing Pleadings, Motions, and Other Papers; Representations to the Court; Sanctions

(a) Signature. Every pleading, written motion, and other paper must be signed by at least one attorney of record in the attorney's name—or by a party personally if the party is unrepresented.

(Implication: An attorney must attest that the filing is a valid legal filing based on valid legal theories, and stakes their position as an officer on the court on that belief.)

Federal Rule of Civil Procedure 11 authorizes sanctions for pleadings filed for an improper purpose, including filing suit to force a settlement. A voluntary dismissal does not foreclose Rule 11 sanctions. Courts also retain inherent authority to sanction bad-faith conduct that abuses the judicial process.

Application

For the 109 days that this case was pending, no attorney representing the United States filed a notice of appearance or any document indicating the government’s position, interest, or awareness of this matter.

These facts lead to the inexorable conclusion that the “settlement” terms, the individuals who signed the “settlement” as well as the putative beneficiaries of the “settlement,” demonstrate a shared, unitary interest.

Conclusion

The Court found there was never adverseness between the parties, never a case or controversy, and never a question as to who would prevail. Therefore the court was unable to hear the case to begin with and any legal ramifications are void ab initio.

The lawsuit was brought for the improper purpose of gaining judicial legitimacy for a settlement with no basis in law or fact.

Therefore the parties are barred from invoking the settlement in any future legal proceeding, making the settlement unenforceable moving forward.

The Court imposed Rule 11 sanctions: referring Plaintiffs' attorney Alejandro Brito to the Florida Bar, denying Daniel Epstein's pro hac vice applications for one year, and directing copies of the order to the New York Bar (Acting AG Todd Blanche) and D.C. Bar (Associate AG Stanley Woodward Jr.). The Court also found bad faith warranting monetary sanctions under its inherent authority.