The D.C. Circuit Affirmed His 2022 Immunity Ruling. Trump Did Not Take That One Up.

DOCUMENTED

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United States Supreme Court Building. Ken Hammond, USDA. U.S. government work.

After the February 18, 2022, opinion, President Trump took an interlocutory appeal on immunity. A D.C. Circuit panel decided Blassingame v. Trump, 87 F.4th 1 (D.C. Cir. 2023). The panel held that, on a motion to dismiss, Trump had not demonstrated entitlement to official-acts immunity for the actions leading up to and on January 6 as alleged. Mehta’s 2026 opinion recites that Trump then elected not to appeal that Circuit decision, and that the case returned for discovery and summary judgment.

A Circuit affirmance of a pleading-stage ruling is not a damages judgment and is not the 2026 summary-judgment opinion. The Supreme Court’s later criminal-immunity decision in Trump v. United States, 603 U.S. 593 (2024), is a different caption. Mehta applied both Blassingame and Trump in the March 31, 2026, civil ruling.

Sources

Mehta, J. Memorandum Opinion, Lee v. Trump, 21-cv-00400 (APM) (Mar. 31, 2026) (recites Blassingame posture). RECAP PDF. storage.courtlistener.com

Thompson v. Trump, 590 F. Supp. 3d 46 (D.D.C. 2022). storage.courtlistener.com

Opinion

The following is commentary by this site. It is not a finding of fact and not a legal conclusion.

Compiler take

The Circuit backed him. Trump did not take that appeal to the Supreme Court. Then the Court wrote a criminal-immunity opinion on a different file. Mehta used both when he came back in 2026.