Lee v. Trump, No. 21-cv-00400 (APM), the lead caption of the consolidated January 6 civil cases that began as Thompson v. Trump. On March 31, 2026, Mehta issued a memorandum opinion on official-acts immunity at summary judgment. Official-acts immunity is the rule that a President is shielded from civil damages for conduct inside the outer edge of the job. The opinion PDF is the primary.
He wrote: “President Trump has not shown that the Speech reasonably can be understood as falling within the outer perimeter of his Presidential duties.” And: “The content of the Ellipse Speech confirms that it is not covered by official-acts immunity.” The Speech is the January 6, 2021, remarks at the Ellipse — the park south of the White House — at the event the opinion calls the Save America Rally and that contemporaneous reporting also called a “Stop the Steal” rally. The holding is that, on the summary-judgment record, the speech was the act of an office-seeker, not an office-holder.
He did not hold that every January 6 act was unofficial. The same opinion denies summary judgment except as to conduct he classified as official, including Rose Garden remarks during the riot and interactions with Justice Department officials. He denied reconsideration of the First Amendment ruling, certified those First Amendment questions for interlocutory appeal, and granted plaintiffs’ motion to strike the United States’ Westfall Act certification. Westfall certification is a Justice Department paper that, if it stood, would have substituted the United States as defendant on tort claims and ended those claims. A summary-judgment ruling is not a trial verdict, not a damages award, and not a Supreme Court holding. The opinion itself states Trump may reassert official-acts immunity at trial under a higher burden.
Associated Press and Politico reported the decision the same day. Those pieces are labeled reporting. They do not replace the PDF.