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With Donald Trump mired in four criminal trials — including a hush-money/election interference case that began on April 15, 2024, plus multiple significant civil cases — he's demonstrated a wide range of behavior in court and just outside the courtroom, from aggro attacks and gag order violations to midday snoozefests. Trump's legal victories have been few and far between amid the current spate of legal drama, but we've spotted some of those, as well.
We're taking a look back at the former president's most memorable courtroom performances, ranking them from worst to best…
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No. 11: 'Sleepy Don' takes Manhattan
Donald Trump's criminal hush-money trial got underway in New York City on April 15, 2024, marking the first time an American president has been tried on criminal charges. Trump faces 34 counts of falsifying business records to conceal hush-money prosecutors say he paid to adult film actress Stormy Daniels in an effort to unlawfully influence the 2016 election. (He's pleaded not guilty.)
Despite the soap opera-worthy backstory and his claims of innocence, Trump, 77, reportedly fell asleep multiple times on the first two days of the trial. The snoozefest quickly spawned memes, cable news chatter and late-night jokes, as hashtags like "Sleepy Don" — a play on Trump's "Sleepy Joe" nickname for President Joe Biden — trended on social media.
"Mr. Trump appeared to nod off a few times, his mouth going slack and his head drooping onto his chest," The New York Times' Maggie Haberman reported on the Times' live blog. "Trump has apparently jolted back awake" after "noticing the notes his lawyer passed him several minutes ago," she later added. Similar reports from Reuters, Courthouse News and Law360.com followed. Trump's campaign dismissed them all as "fake news," while late-night host Jimmy Kimmel suggested it may have been part of the defense's legal strategy.
"He's so sleepy," Kimmel said in his monologue after Trump's second day of courtroom zzz's. "Is it possible his lawyers are tranquilizing him to keep the outbursts at a minimum?"
Perhaps, but the optics of a sleeping through one's own criminal trial while running for office aren't so good. Then again, a wide-awake Trump in court has downsides, too…
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No. 10: Almost ejected
Courtroom naps were certainly not on the docket for Donald Trump in January 2024 as a New York City jury sought to determine the amount he should pay writer E. Jean Carroll for defaming her by denying her sexual assault claims during his presidency. Trump, who'd already been found liable for the assault, was not required to attend the hearings, despite his claims to the contrary. But on Jan. 17, 2024, he was there — and he was so disruptive that the judge threatened to kick him out of the courtroom.
As Carroll told the jury how Trump's false claims about her had destroyed her career and led to threats of violence, the former president "shook his head," "exhaled loudly," "whispered to his lawyer" and "muttered 'con job' and 'witch hunt,'" multiple outlets reported. Carroll's lawyer finally told Judge Lewis Kaplan that Trump was commenting loudly about the case within earshot of jurors.
In response, Kaplan warned that while Trump had "the right to be present" in court, "that right can be forfeited … if he is disruptive and if he disregards court orders," per NBC News. "Mr. Trump, I hope I don't have to consider excluding you from the trial. I understand you are probably very eager for me to do that," the judge told Trump.
"I would love it. I would love it!" Trump replied, throwing his hands up.
"I know you would because you just can't control yourself in this circumstance, apparently," said the judge.
"You can't either!" Trump shot back.
After a slew of similarly heated exchanges, the jury ordered Trump on Jan. 26, 2024, to pay Carroll $83.3 million. That's more than eight times what Carroll asked for when she brought the suit, so we're giving the former president's testy Jan. 17, 2024, court performance a big thumbs-down.
No. 9: Witness stand mayhem
On Nov. 6, 2023, Donald Trump took the stand in his New York civil fraud case and it was, in a word, mayhem. Accused of inflating the value of his real estate portfolio and net worth by more than $2 billion, Trump's testimony featured rambling attacks against Judge Arthur Engoron, New York Attorney General Leticia James — who'd been investigating the Trump Organization for fraud since 2019 — and others. Trump was "belligerent and brash, unrepentant and verbose" on the stand, calling James a "political hack," according to The New York Times. "He called me a fraud, and he didn't know anything about me!" Trump reportedly yelled from the witness stand while pointing at the judge.
Engoron chastised Trump for giving "irrelevant" non-answers on the stand and eventually asked the former president's lawyers to control him, warning the former POTUS that "this is not a political rally."
Trump's aggression wasn't the only aspect of his performance that may have worked against him that day. He also inflated the value of at least one property in the course of his testimony, saying his Trump Tower triplex was "11,000 square feet" — its actual size — then calling it "12,000 square feet" and, finally, "13,000 square feet."
In February 2024, Engoron found Trump and his companies had conspired for years to defraud banks and others with false financial assessments. Trump was ordered to pay $464 million — but more on that later…
No. 8: Irking Judge Engoron
By the time Donald Trump was ordered to come up with $364 million in his New York civil fraud trial in February 2024, his behavior had already cost him plenty in court.
Just two days into the trial, Judge Arthur Engoron issued a gag order on "all parties" to prevent them from speaking about members of the court staff after Trump made false claims about the judge's law clerk on Truth Social. The post was taken down right after the order on Oct. 3, 2023, according to CNN. More than two weeks later, however, Engoron found the same incriminating and derogatory post on Trump's website. He fined the former president $5,000 and warned that further violations could result in heavier penalties including jail time.
"Trump has received ample warning from this Court as to the possible repercussions of violating the gag order. He specifically acknowledged that he understood and would abide by it," Engoron wrote in the order on Oct. 20, 2023. "Accordingly, issuing yet another warning is no longer appropriate; this Court is way behind the 'warning' stage."
While Engoron allowed that the post's appearance on DonaldJTrump.com may have been inadvertent, he was less forgiving six days later, when Trump violated the gag order again.
No. 7: Irking Engoron 2.0
Act II! On Oct. 26, 2023, Donald Trump violated Judge Arthur Engoron's gag order once again — this time, the former president's performance earned him a $10,000 fine.
Speaking to reporters outside the courtroom during his New York civil fraud trial, Trump took another swipe at the law clerk he'd attacked just one week earlier. "This judge is a very partisan judge with a person who is very partisan sitting alongside him – perhaps even much more partisan than he is," he said, presumably referring to the clerk who spent the bulk of the trial at Engron's side. When Engoron caught wind of Trump's remarks, he stopped the proceedings to hold a hearing and called Trump to the witness stand, citing the "overheated environment" of the 2024 campaign trail, and saying he was protecting his staff for their safety, according to CNN.
On the stand, Trump claimed his comment was in reference to his former fixer Michael Cohen, not the clerk. The judge seemed unmoved and asked Trump if he'd previously called the law clerk a "partisan Democrat." Trump replied, "I think she's very biased against us. I think we've made that clear." He was then slapped with the $10,000 fine.
No. 6: 'Trump bump' distraction
As we inch closer to Donald Trump's best courtroom performances amid his latest legal drama, we can't help but recall the memorable court-adjacent moment that gave rise to the phrase "Trump bumps." As he headed to a second day of testimony in E. Jean Carroll's defamation case against him on Jan. 17, 2024, Trump flashed a wave at photographers outside Trump Tower in New York City.
Photos of the wave showed mysterious red splotches on his fingers, thumb and hand. While some on social media suggested he may have cut himself while dealing with papers related to the hearing, others pitched quippy names for the apparent affliction (see above). Still others aligned themselves with James Carville, who said during a Politicon livestream, "They don't look like cuts to me, they look like sores."
We never got a conclusive answer on the red stuff, but it briefly distracted us from the charges at hand (ahem). Moving on…
No. 5: Jail baiting the judge
Donald Trump has said it would be his "great honor" to go to jail for violating the gag order against him in his criminal hush-money case — and he just might get his wish, thanks to his ongoing Truth Social posts about the trial.
As jury selection continued in Judge Juan Merchan's New York City courtroom on April 18, 2024, prosecutors said Trump had violated the order seven times already that week. They cited Truth Social posts in which Trump shared links and quotes featuring attacks on his former fixer Michael Cohen, a potential witness, and potential jurors, whom he called "undercover liberal activists lying to the judge," attributing the claim to commentator Jesse Waters, Politico reported.
"It's ridiculous and it has to stop," said prosecutor Chris Conroy, per CNN.
The expanded gag order bars Trump from making comments about potential witnesses, jurors, court staff or members of their families. It was instituted after Trump repeatedly attacked the judge's daughter online and made false allegations about her social media posts. The prosecution's latest list of alleged gag order violations comes two days after they filed a motion to hold Trump in contempt of court for previous posts they said violated the order.
No. 4: Jury-adjacent commentary
During jury selection in Donald Trump's criminal hush-money case on April 16, 2024, Judge Juan Merchan chastised both Trump and his lawyers after he spotted the former president "muttering" and "gesturing" at a potential juror when she was "12 feet away" from him.
"Your client was audibly uttering something," Merchan snapped at Trump's attorney Todd Blanche, per CNN. "I won't tolerate that. I will not have any jurors intimidated in this courtroom. I want to make that crystal clear."
When the judge directed Blanche to get Trump to pipe down and knock it off, Trump was reportedly "slumped in his seat, sitting as though he were in a lounge chair," CNN reported. To his credit, Trump seemed to abide by the judge's command, earning him a few extra points in the old courtroom performance tally.
No. 3: Bond reduction magic
Things were looking grim for Donald Trump in the wake of his $464 million New York civil fraud judgment. But on March 25, 2024, the former president's legal team scored a major win on his behalf, when the bond was reduced to $175 million and Trump was given an extra 10 days to pay the fine. If he didn't, New York Attorney General Leticia James made it clear she was prepared to seize his assets.
With Trump's legal fees mounting in other cases — alongside his ongoing presidential campaign costs — the reduced bond and extra time offered an unexpected lifeline. But the chances of his finding a way to come up with the money seemed unlikely, at best. Until…
No. 2: Bond by Knight
On April 1, 2024, Donald Trump's attorney Alina Habba confirmed the former president had posted the $175 million bond in his New York fraud case, giving him time to continue his appeal.
"He looks forward to vindicating his rights on appeal and overturning this unjust verdict," Habba said in a statement.
CNN later reported that the bond was underwritten by Knight Specialty Insurance and that "Trump posted all cash as collateral." The outlet added that the California-based company, which specializes in subprime auto loans for people with bad credit, reached out to Trump first.
"I'm happy to do it. We would have done it for anybody else," the company's chairman, Don Hankey, said in an interview.
The bond payment feels like a solid No. 2 in Trump's worst-to-best courtroom performances, which brings us to our contender for his No. 1 best…
No. 1: Micky D's day
And the No. 1 best performance we've seen from Donald Trump in court is… McDonald's related.
On Oct. 2, 2023, Trump made his first courtroom appearance in the New York fraud trial brought against him by Letitia James — and he came prepared. Photos showed the former president and avowed fast food superfan's security staffers heading into Manhattan Supreme Court with at least six bags of takeout from Mickey D's.
Since the presumptive Republican nominee has yet to be sued for his dietary decisions, we can't help but applaud an appropriately frugal lunch option for a not-so-economical lawsuit.