How did the D.C. and New York courts handle immunity arguments in Trump’s cases and what were their findings?
Executive summary
The D.C. courts initially rejected former President Trump’s sweeping claim of blanket criminal immunity for actions around January 6, allowing federal prosecution to proceed, a ruling the D.C. Circuit unanimously affirmed before the Supreme Court later crafted a narrower immunity framework that gave presidents absolute immunity for a “core” of official acts and presumptive immunity for others [1] [2] [3]. In New York, state judges repeatedly found the Manhattan hush‑money prosecution concerned “unofficial” conduct and therefore not barred by presidential immunity, though the post‑Supreme Court fight shifted to whether evidence of official acts could be admitted or would be excluded [4] [5] [6].
1. How the D.C. district court framed and denied the immunity claim
U.S. District Judge Amit Mehta rejected Trump’s argument that his January 6 speech and related conduct were protected as presidential “official acts,” finding those actions were aimed at securing another term rather than performing a presidential function and thus were not within the protective outer perimeter of immunity established by Nixon v. Fitzgerald [1] [7]. The D.C. Circuit panel unanimously upheld Mehta’s ruling, emphasizing that Trump had acted “as office‑seeker, not office‑holder,” and allowed the civil claims by members of Congress and police officers to proceed [2] [1]. The rulings in D.C. were explicit rejections of a blanket immunity defense: the lower courts required closer, case‑specific inquiry into whether particular acts were official before excusing them from civil or criminal accountability [1] [8].
2. The Supreme Court’s intervention and the new contours of immunity
The Supreme Court granted review and in July 2024 issued a 6–3 decision that reframed presidential immunity: it held presidents are absolutely immune for a narrow “core” of constitutional functions, presumptively immune for acts within the “outer perimeter” of official responsibility, and not immune for unofficial acts — but it left significant doctrinal questions open and remanded aspects of the lower‑court work for further proceedings [3] [2] [9]. The high court also recognized that even when prosecutions concern unofficial acts, courts may preclude the government from presenting evidence of official conduct for which a president would be immune, creating a potentially dispositive evidentiary doctrine distinct from dismissal of charges [4] [3]. Civil and criminal litigants and judges were therefore given a hybrid rule: immunity may bar prosecution of some official acts and may bar or limit the use of official‑act evidence even when charges allege unofficial wrongdoing [3] [4].
3. New York state courts: conviction, evidentiary fights, and procedural maneuvering
In Manhattan, Justice Juan Merchan and other New York judges repeatedly found that hush‑money payments and reimbursements to Michael Cohen were not presidential functions and thus not protected by presidential immunity, with lower‑court findings and trial rulings concluding the payments were unrelated to constitutional duties [4] [5]. After the Supreme Court’s immunity decision, Trump sought to vacate his conviction and to remove the case to federal court, arguing the ruling required exclusion of evidence or dismissal; prosecutors in Manhattan countered that the decision affects admissibility of evidence but not the underlying state charges, and state judges and later a federal judge scrutinized the timing and procedural posture of those removal requests [6] [5]. New York judges have therefore treated immunity primarily as an evidentiary and scope question — whether official‑act evidence can be used — rather than a blanket bar to the state prosecution itself [4] [6].
4. Where the decisions converge, diverge, and why agendas matter
Across D.C. and New York the core pattern is consistent: courts demand concrete factual analysis to separate official from unofficial acts rather than accepting a categorical presidential shield [1] [4]. The Supreme Court’s later narrowing in 2024 pulled part of the legal rug out from under those lower‑court rejections by elevating a categorical core immunity and a presumptive zone, but it simultaneously created an evidentiary exclusion that benefits defendants while leaving many factual disputes for trial judges to resolve [3] [4]. Political and institutional agendas are visible: defense teams pressed maximalist immunity arguments to foreclose prosecutions, prosecutors emphasized the narrowness of official functions to preserve accountability, and civil‑liberties groups warned the Supreme Court’s outcome places presidents above the law — all framing that shapes litigation strategy and public perception [10] [8].
5. Bottom line for the cases
D.C. courts initially denied Trump’s immunity claims and advanced prosecutions and civil suits by treating alleged January 6 activities as non‑official [1]; New York courts likewise rejected immunity for the hush‑money scheme as outside presidential duty but have had to confront post‑Supreme Court disputes over whether officials’ conduct evidence must be excluded or trials affected [4] [6]. The Supreme Court’s 2024 ruling altered the doctrinal map — recognizing absolute immunity for a narrow set of core acts and presumptive immunity elsewhere, while creating an important evidentiary exclusion — but left lower courts to apply those principles case‑by‑case, meaning litigation over immunity in both D.C. and New York continues as a live, fact‑intensive contest [3] [4] [2].