President Donald Trump's lawyers told a federal appeals court Tuesday the president faces "tortious injury" without a stay of a sanctions order voiding his IRS audit deal.
The motion, filed Tuesday in the 11th U.S. Circuit Court of Appeals, asks the court to pause U.S. District Judge Kathleen Williams's July 13 sanctions order while Trump appeals.
If the deal is restored, it could shield the president from a potential $100 million tax bill — and wipe out sanctions that have already put two of his lawyers' careers in jeopardy.
The filing repeatedly attacked Williams, a judge appointed by former President Barack Obama. The motion argues the judge's gag order is so sweeping it covers the appeal itself — barring the parties from even referencing the settlement they are fighting to revive.
"It is so sweeping that, theoretically, Movants risk violating it merely by appealing it, which underscores how violently the Sanctions Order violates the Constitution," the motion states. "When a court sanctions parties for advancing a legal position and then forbids the speech necessary to challenge that sanction, your very legal system is in danger."
Even as the $1.776 billion anti-weaponization fund was scrapped, the audit immunity survived, Time reported.
That immunity could shield Trump from a $100 million bill tied to a long-running IRS audit of his Chicago skyscraper, Time reported.
Trump's lawyers also challenged Williams's ruling on statutory grounds, arguing the underlying law gives the president no special exemption from suing his own government.
"On its reasoning, a President tortiously injured inside a federal building would be the one person in America without a remedy," the motion states.
The motion also faults Williams for imposing sanctions without notice, evidence, or individualized findings against any specific lawyer, according to the filing.
Williams issued her 56-page ruling on July 13, two days before Attorney General Todd Blanche's Senate confirmation hearing, CNN reported.
"The proceedings here delivered the opposite: undisclosed theories, baseless accusations of bad faith, and career-altering sanctions — rushed out just two days before then-Acting Attorney General Blanche's confirmation hearing, in an opinion littered with obvious legal, factual, and technical errors," the motion states.
Trump's lawyers called the timing "suspicious" in a footnote — citing a National Review piece rather than making the accusation outright.
Trump filed his $10 billion lawsuit against the IRS in January 2026, suing an agency he controls over the leak of his tax returns between 2019 and 2020, according to the filing.
By May, the two sides had settled — Trump dropping the lawsuit in exchange for audit immunity and the anti-weaponization fund, Forbes reported.
Williams voided the deal, finding the case was "brought to manipulate the judicial process," CNN reported.
The IRS and Justice Department declined to oppose the stay, though 35 former federal judges who intervened to challenge the settlement are expected to fight it, the motion states.
Attorney Alejandro Brito has been referred to the Florida Bar; attorney Daniel Epstein is barred from appearing in the Southern District of Florida for one year — a ban that may expire before the appeal is resolved, the motion warns.
Williams denied Trump's request for an expedited stay on August 5, saying plaintiffs had "not shown good cause," leaving all sanctions in force as the 11th Circuit takes up the case, Law & Crime reported.
