Disbarment and Dismissal: The Legal Tailspin of Rudy Giuliani

It is safe to say we have all had bad weeks, but former New York City Mayor Rudy Giuliani takes it to an entirely different level. Dealing with both a high-profile disbarment and a total collapse of his bankruptcy protection, Giuliani’s legal woes provide a textbook example of what happens when a debtor tries to play games with the federal court.

MANCHESTER, NEW HAMPSHIRE – JANUARY 21: Rudy Giuliani speaks to members of the media where Republican candidate Florida Gov. Ron DeSantis was scheduled to host a campaign event on January 21, 2024 in Manchester, New Hampshire. Gov. DeSantis has suspended his presidential campaign and is endorsing Republican candidate, former President Donald Trump. (Photo by Brandon Bell/Getty Images).

Updated on June 2, 2026.

By Alexander Hernandez, J.D., Professor, and Author of Consumer Bankruptcy Law (Routledge).

Key Points:

• Loss of Bar License: Rudy Giuliani was officially disbarred from practicing law in the state of New York following his actions surrounding the 2020 election results.
• The $148 Million Judgment: The financial catalyst for his downfall was a massive $148 million defamation judgment won by Georgia election workers Ruby Freeman and Shaye Moss.
• The Chapter 11 Failure: While Giuliani initially sought Chapter 11 reorganization, his case was dismissed by a federal judge.
• The Alex Jones Parallel: Like InfoWars’ Alex Jones, Giuliani tried to use bankruptcy as a shield against intentional tort judgments, but both discovered that federal bankruptcy courts will not tolerate bad-faith filings or protect non-dischargeable debt.

Rudy Giuliani Disbarred from the Practice of Law

On July 2, 2024, the Supreme Court of New York Appellate Division, First Judicial Department, officially stripped Rudy Giuliani of his law license.

On July 2, 2024, the Supreme Court of New York Appellate Division, First Judicial Department, officially stripped Rudy Giuliani of his law license.

As a practicing attorney with over 26 years of experience, I can tell you firsthand that losing your license is a lawyer’s ultimate nightmare. We spend our entire lives building a reputation. Occasionally getting into legendary, courthouse-lore screaming matches with judges (including one family court judge, now deceased, whom I’ll never forget). But none of that courthouse gossip compares to the absolute devastation of losing the bar license you sweated blood to earn and keep.

Attorneys live in perpetual fear of administrative overreach. If a lawyer goes out for two drinks with friends, they spend the whole drive home sweating bullets about a potential DUI, not just because of the criminal penalties, but because a bar complaint can instantly freeze your livelihood.

Some jurisdictions are notoriously aggressive. Take Florida, for example. If an attorney is arrested there, the Florida Bar will often suspend them pending the outcome of the criminal case.

Even if the charges are completely dropped later, your practice has been starved of income for months or years. That is why lawyers file immediate appeals to delay administrative penalties while fighting the underlying claims.

I’ve dealt with this firsthand. Years ago, when preparing to sell my practice, I emailed attorneys licensed in Florida to see who might be interested in acquiring the firm.

• Clown Lawyer #1 immediately began making absurd demands, trying to launch a ridiculous class-action lawsuit over a simple marketing email.
• Clown Lawyer #2 went a step further and filed a formal bar complaint, claiming that looking for a successor to buy my firm was somehow unethical and illegal.

Was I worried about losing my license? Not for a second. I knew the law inside and out, and six months later, the Florida Bar dismissed the complaint with a letter that read like a literal carbon copy of my defense response. It was a massive waste of everyone’s time. For the record, I don’t wish bad on those clown lawyers, but I sure as hell don’t wish them well.

The Chapter 11 Strategy and the “Willful and Malicious” Trap

Giuliani fled to the safety of the bankruptcy court after a federal jury handed down a devastating $148 million defamation judgment to mother-daughter Georgia poll workers Ruby Freeman and Shaye Moss. Their heartbreaking testimony before the January 6th House Committee gave the entire country an inside look at how Giuliani’s public statements completely upended their personal safety and livelihoods.

To cut through the disinformation surrounding this case: Giuliani did not lose this trial on a technicality. In the underlying lawsuit, he formally stipulated that his actions were “intentional, malicious, wanton, and willful.“ By signing off on that legal language, he didn’t even contest the liability—he conceded it. The entire trial was strictly about calculating the damages.

For everyday consumers, this stipulation is a massive bankruptcy error. Under 11 U.S.C. § 523(a)(6) of the Bankruptcy Code, any debt arising from a “willful and malicious injury by the debtor to another” is completely non-dischargeable. By admitting his conduct was willful and malicious, Giuliani essentially guaranteed that this $148 million debt could never be wiped out in bankruptcy, regardless of what chapter he filed under.

Why Rudy Giuliani’s Bankruptcy Was Completely Tossed Out

Giuliani seemed to have taken a page out of InfoWars founder Alex Jones’ playbook. Jones filed for Chapter 11 protection, facing a $1.5 billion judgment from the Sandy Hook Elementary School shooting victims’ families after spending years falsely claiming they were “crisis actors.” Jones eventually tried to convert his case to a Chapter 7 liquidation when his reorganization fell apart.

Giuliani attempted a similar maneuver. His unsecured creditors’ committee, the group appointed in a Chapter 11 to ensure creditors get paid, grew furious with him. They accused him of hiding assets, failing to file mandatory monthly operating reports, and using his cash to pay for personal luxuries, including his girlfriend’s daughter’s credit card bills. (Side note: Giuliani is 80 years old. Can we please retire the terms “boyfriend” and “girlfriend” once we’re decades removed from high school? But I digress.)

When the creditors demanded that the court appoint an independent Chapter 11 Trustee to seize total control of his finances, Giuliani’s legal team panicked and tried to convert the case to a Chapter 7 liquidation.

Why the Bankruptcy Judge Said “No”

In an ordinary consumer bankruptcy, a debtor has an absolute right to convert a Chapter 11 to a Chapter 7. However, U.S. Bankruptcy Judge Sean Lane stepped in and did something far worse for Giuliani: he dismissed the entire bankruptcy case altogether.

In an ordinary consumer bankruptcy, a debtor typically holds a right to convert a case under 11 U.S.C. §1112(a) from Chapter 11 to Chapter 7 liquidation. However, that right is not absolute if bad faith or a failure to maintain financial transparency is present.

Exercising his authority under 11 U.S.C. § 1112(b), U.S. Bankruptcy Judge Sean Lane stepped in and did something far worse for Giuliani: finding “cause” due to gross mismanagement and failure to cooperate, he dismissed the entire bankruptcy case altogether.

The judge slammed Giuliani as a “recalcitrant debtor,” noting that “transparency into Mr. Giuliani’s finances has proven to be an elusive goal” and highlighting his outright refusal to even hire an accountant.

By dismissing the case rather than converting it to a Chapter 7 liquidation, the judge did two major things that everyday consumers need to understand:

1. The Automatic Stay is Dead: Giuliani is no longer protected from foreclosures, repossessions, or bank levies under §362.
2. The Assets are Fair Game: Ruby Freeman and Shaye Moss don’t have to wait for a bankruptcy trustee to settle the bankruptcy estate. They can move forward with aggressive civil collections, meaning they can directly seize and force the sale of his luxury New York City apartment and his Palm Beach, Florida condo.

Giuliani claimed Florida residency in a desperate bid to shield his Palm Beach condo under Florida’s famously generous homestead exemption. But because he completely flouted court transparency guidelines, he lost the right to bankruptcy protections entirely and is barred from refiling for a full year.

The Bottom Line for Consumers

The bankruptcy court is a court of equity. If you show up with “unclean hands,” hide bank statements, funnel money through unlisted business accounts, or treat court deadlines as suggestions, the judge will not help you. You will find yourself thrown out of court and left completely vulnerable to your collectors.

Educational Resources

• For Institutions: Colleges and universities can purchase or request examination copies of my textbook directly from Routledge Publishing.
• For Students & Practitioners: Single print and digital copies are available via Amazon Books.
• Video Lectures: Stream comprehensive legal breakdowns and video explanations on the Prof. Hernandez YouTube Channel.

Bankruptcy Court & Consumer Resources

Explore a deep dive for consumer guides and court directories to navigate your legal options:

• A step-by-step master guide on Filing for Bankruptcy and Navigating the Petition.
• Access full directories for the Federal Bankruptcy Court System and Trustee Contact Information.
• Protect your assets by reviewing your specific State Bankruptcy Exemptions or compare them against the Federal Bankruptcy Exemptions.
• Prepare for your court date with the updated brief on the 341 Meeting of Creditors Rules and Procedures.

Please note that the information on this site does not constitute legal advice and should be considered for informational purposes only.

Bankruptcy Statutory References

• 11 U.S. Code §523 – Exceptions to discharge.
• 11 U.S. Code §1112 – Conversion or dismissal.
• 11 U.S. Code §362 – Automatic stay.