More: Gayles said Trump's complaint "falls short of pleading actual malice," and also said the president "comes nowhere close to" the standard for showing that the newspaper deliberately avoided investigating the truth of the statements it published about the letter.

"The Article explains that, before running the story, Defendants contacted President Trump, Justice Department officials, and the FBI for comment," the judge wrote. "President Trump responded with his denial, the Justice Department did not respond at all, and the FBI declined to comment. In short, the Complaint and Article confirm that Defendants attempted to investigate."