U.S. District Judge Jed S. Rakoff of the Southern District of New York rejected Sarah Palin's motion to retroactively disqualify him or hold a new trial in her defamation case against The New York Times, finding that her motion is "wholly lacking in merit."

Attorneys for the former Alaska governor and Republican vice presidential nominee raised objections to Rakoff's conduct and argued that the verdict was tainted by the push notifications jurors received regarding Rakoff's unusual decision to make a legal ruling in the case while they were still deliberating. Rakoff previously ruled that it was "implausible" that the push notifications affected the verdict.