Giuliani's $148 Million Defamation Verdict: Consequences for Spreading Trump's Election Fraud Claims Against Georgia Election Workers
Tier 1Resolved2020-12-03 to 2024-12-19
Factual Summary
On December 15, 2023, a federal jury in Washington, D.C. awarded Ruby Freeman and her daughter Wandrea "Shaye" Moss a total of $148,169,000 in compensatory and punitive damages after finding that Rudy Giuliani had defamed them by repeatedly and falsely accusing them of committing election fraud while they served as poll workers in Fulton County, Georgia, during the 2020 presidential election. Giuliani was acting as Donald Trump's personal attorney when he made the statements. The verdict is the largest known defamation award against a single individual connected to the post-2020 election fraud claims.
The case arose from a series of public statements Giuliani made beginning in December 2020, when he appeared before a Georgia state legislative hearing and played a selectively edited surveillance video that he claimed showed Freeman and Moss pulling suitcases of fraudulent ballots from under a table and scanning them after observers had been sent home. Giuliani identified Freeman and Moss by name and accused them of being "professional vote scammers" and "quite obviously surreptitiously passing around USB ports as if they are vials of heroin or cocaine." Georgia election officials, the FBI, and the Georgia Bureau of Investigation all investigated the video and concluded that it showed normal ballot processing procedures. No evidence of fraud was found.
Freeman and Moss testified about the devastating consequences of Giuliani's accusations. They received death threats, racist harassment, and threats of physical violence. Moss, who had worked as a Fulton County elections supervisor, was forced to leave her job. Freeman was forced to leave her home after strangers appeared at her door. At trial, both women described the emotional trauma of being publicly accused of undermining American democracy.
The jury awarded $16,171,000 to Freeman for defamation, $16,998,000 to Moss for defamation, $20,000,000 to each woman for intentional infliction of emotional distress, and $75,000,000 in punitive damages. Giuliani did not dispute liability at trial because the court had previously entered a default judgment on the defamation claims after Giuliani failed to comply with discovery orders. The trial addressed damages only.
Shortly after the verdict, Giuliani filed for Chapter 7 bankruptcy, listing assets of approximately $1.5 million and debts exceeding $148 million. The bankruptcy was dismissed in August 2024 after a judge found that Giuliani had failed to meet his obligations under the bankruptcy process. A federal judge subsequently ordered Giuliani to turn over virtually all of his property to Freeman and Moss within seven days, including his New York City apartment, more than two dozen luxury watches, a 1980 Mercedes-Benz once owned by actress Lauren Bacall, and sports memorabilia. As of late 2024, court filings indicated that Giuliani had satisfied the judgment, though the mechanism of satisfaction and whether Freeman and Moss received the full $148 million has not been publicly detailed.
Primary Sources
1. Freeman v. Giuliani, No. 1:21-cv-03354 (D.D.C.), jury verdict, December 15, 2023
2. Default judgment on liability, Freeman v. Giuliani, entered for failure to comply with discovery orders
3. Bankruptcy filing, In re Rudolph W. Giuliani, Chapter 7 (filed December 2023, dismissed August 2024)
4. Asset turnover order, Freeman v. Giuliani, October 2024
5. Georgia Secretary of State investigation and FBI investigation clearing Freeman and Moss of any election fraud
Corroborating Sources
1. Protect Democracy: "Jury Awards Ruby Freeman and Shaye Moss $148,169,000 in Damages"
2. NPR: "Rudy Giuliani ordered to turn over luxury watches, Mercedes in defamation suit," October 22, 2024
3. ABC News: "Rudy Giuliani loses bid to dismiss $148 million defamation judgment in Georgia election workers case," 2024
4. CNN: "Will the Georgia election workers see any of the $148 million award from Rudy Giuliani?" December 16, 2023
5. NBC News: "Judge OKs deal to dismiss Rudy Giuliani bankruptcy case in step toward collection of $146M defamation verdict," 2024
Counterarguments and Context
Giuliani maintained that his statements about Freeman and Moss were protected political speech and that he was raising legitimate concerns about election integrity. His legal team argued that the default judgment on liability was procedurally unfair and that the damages award was grossly excessive. Supporters of Giuliani argued that raising questions about election procedures is protected under the First Amendment and that the verdict would have a chilling effect on political speech. However, Giuliani's liability was established by default only after he repeatedly failed to comply with court-ordered discovery, a pattern the judge characterized as willful noncompliance. The underlying factual claims were investigated by multiple agencies and found to be baseless. The surveillance video Giuliani cited was determined to show standard ballot processing, not fraud. While Giuliani was the named defendant, he made these statements in his capacity as Trump's personal attorney, acting on behalf of Trump's broader campaign to challenge the 2020 election results. Trump personally repeated claims about election fraud in Georgia, including specifically referencing the Fulton County ballot processing, though Trump was not a defendant in this case.
Author's Note
This entry is classified as Tier 1 because the case proceeded through a full jury trial (on damages) and resulted in an enforceable judgment that Giuliani has been ordered to satisfy. While Giuliani was the defendant rather than Trump, the defamatory statements were made in Giuliani's role as Trump's personal attorney, advancing claims about election fraud that Trump himself was simultaneously promoting. The case is included in The Ledger because it represents a direct, adjudicated legal consequence of the post-2020 election fraud narrative that Trump initiated and Giuliani amplified. The human cost to Freeman and Moss, documented in their trial testimony, illustrates the real-world impact of false election fraud allegations on individual citizens.