ENTERTAINMENT
Blake Lively’s First 47.1 Fee Award Is $407,000
A New York judge issued the first fee award under California’s 47.1 law, then cut Blake Lively’s $8 million Baldoni bill to $407,000.
A Manhattan federal judge awarded Blake Lively $407,451.75 in fees and costs on Wednesday, about 5 percent of the $8.04 million she sought from Justin Baldoni. Judge Lewis J. Liman of the Southern District of New York limited the payout to her defense of Baldoni’s dismissed defamation claim and wrote that the hours on her bill were unreasonable.
Her lawyers still called the result historic. His lawyer called it a win. The order does both jobs at once.
Liman Measured Lively’s Fees Against the Times’ Bill
Lively asked for $8,035,040.88, made up of $7,495,526.87 in attorneys’ fees and $539,514.01 in costs, after Baldoni and Wayfarer Studios LLC lost a $400 million defamation case against her. Wayfarer told the court the figure was so inflated it should be denied altogether, and pointed to a much smaller number from the same fight: the $181,622.70 The New York Times sought for beating a related defamation claim.
Liman took that Times figure and used it as a ruler. In a 21-page opinion, he awarded Lively double the Times’ own fee request, which comes out to exactly $363,245.40 in fees, plus $44,206.35 in costs.
| Who billed | Amount sought | Amount awarded |
|---|---|---|
| Blake Lively (fees and costs) | $8,035,040.88 | $407,451.75 |
| Lively fees only | $7,495,526.87 | $363,245.40 |
| New York Times fee request (Liman’s benchmark) | $181,622.70 | Used as the base, then doubled |
| New York Times, separate state anti-SLAPP case | $181,622.70 | $171,616.20 (July 27, Justice Gerald Lebovits) |
The doubling is the part the wire copy mostly skipped. Baldoni’s team offered the newspaper’s bill as proof Lively’s ask was about 20 times a comparable defamation defense. The court did not zero her out. It also did not wander into the $8 million neighborhood. It copied the Times’ number, multiplied by two, and stopped.

How the $8 Million Fee Request Was Cut
Two firms carried the $7.5 million fee request: Willkie Farr & Gallagher LLP and Manatt, Phelps & Phillips LLP. Lively’s lawyers had argued the work was comprehensive, necessary, and intertwined with the rest of the case. Liman agreed the billing rates were not unreasonable for a high-stakes fight with complex issues. He did not agree that all those hours belonged on a 47.1 invoice.
People magazine and NBC News both quote the same line from the ruling: “The number of hours for which Lively seeks reimbursement is unreasonable.” The Hollywood Reporter quotes another: “Media relations were not integral to defending the defamation claim brought against Lively.” Time spent on press coverage, the order says, is not compensable.
THE CUTS LIMAN MADE
- The hours: He refused to treat the whole 18-month war as one recoverable defamation defense.
- Press work: Media relations and coverage time came out of the bill.
- The cutoff date: He saw no basis for fees after June 9, 2025, the day the defamation claim was dismissed with prejudice.
- Reputation study: Lively identified $173,276.50 billed by GBX Holdings LLC to assess harm to her name; that item does not appear in the $44,206.35 costs award.
- Travel and discovery: He did pay $11,721.86 in travel tied to court and $32,329.69 in discovery costs from before the June 9 cutoff, which make up nearly all of the costs line.
The remaining math is brutal in a quiet way. Reuters put the award at about 5 percent of the $8.04 million request. Bryan Freedman, lead counsel for Baldoni and Wayfarer, told USA Today the court awarded “only 5 percent of the amount sought” and called Lively’s demand outrageous and unreasonable. He said the ruling was “a significant victory for my clients.”
California’s 47.1 Law Stops at the Defamation Claim
The money comes from California Civil Code Section 47.1, a 2023 statute aimed at retaliatory defamation suits against people who speak about sexual assault, harassment, or discrimination. A prevailing defendant is entitled to reasonable attorney’s fees and costs for winning that defense, plus treble damages for harm caused by the defamation action, and punitive damages under other California law.
SECTION 47.1, IN THE STATUTE’S OWN TERMS
- The privilege: A communication made without malice about sexual assault, harassment, or discrimination is privileged.
- Who it covers: Someone who has, or had, a reasonable basis to file a complaint, whether a complaint was filed or not.
- The stick: Fees, costs, treble damages, and punitive damages for a prevailing defendant in the defamation case.
On June 12, Liman found Lively qualified as that prevailing defendant. He found she had a reasonable basis for her claims and that Wayfarer had not shown malice. He also denied the treble and punitive damages her motion sought, holding those extra remedies were not available in this federal proceeding. Wednesday’s order was only about how large the fee check would be.
Willkie, which represented Lively with Manatt, had already described the June ruling as the first fee award under the statute in federal court, and the first time a prevailing defendant recovered fees under 47.1 at all. The firm said it beat arguments that the law is unconstitutional, that it does not apply in federal court, and that it does not apply when a defamation suit is dismissed on other grounds.
Then came the fight over the word “litigation.” Lively said 47.1 covers the whole case in which a defamation count appears. Wayfarer said it covers only the work needed to beat that count. Liman sided with Wayfarer. Defamation, he wrote, was one claim among others, including civil extortion, implied covenant, and interference theories that did not ride on her sexual-harassment statements.
There is nothing in the law or in the legislative history that indicates that the California Legislature intended to award a defendant accused of a range of tortious conduct other than a SLAPP lawsuit all of her fees and costs in defending against that conduct simply because the person who is the target of that conduct has included in his or her lawsuit a claim for defamation.
Judge Lewis J. Liman, Opinion and Order, U.S. District Court for the Southern District of New York
That reading is the quiet half of the “historic” win. The statute still applied. The check still shrank to the defamation lane, and the treble-damages lane was already closed.
$400 Million, Dismissed With Prejudice
The fee fight only exists because Baldoni and the Wayfarer parties sued Lively, her husband Ryan Reynolds, publicist Leslie Sloane, and Vision PR after she went to the California Civil Rights Department and then to federal court. Their complaint, later expanded to include The New York Times, sought $400 million and alleged defamation, civil extortion, and a string of business torts. Liman dismissed that amended complaint on June 9, 2025. Wayfarer did not refile the claims it was allowed to amend.
THE ROAD TO WEDNESDAY’S NUMBER
- December 20, 2024: Lively files an administrative complaint with the California Civil Rights Department over alleged harassment and retaliation on the set of It Ends With Us and in the film’s marketing.
- December 31, 2024: She sues Baldoni and the Wayfarer parties in Manhattan federal court.
- January 2025: Wayfarer sues Lively, Reynolds, Sloane, and Vision PR; a January 31 amended complaint adds the Times.
- June 9, 2025: Liman dismisses Wayfarer’s amended complaint, including the defamation count, with limited leave to amend that Wayfarer does not use.
- September 8, 2025: Lively moves for fees, treble damages, and punitive damages under Section 47.1.
- April 2, 2026: Liman tosses her sexual-harassment claims, finding she was an independent contractor, and leaves retaliation, aiding-and-abetting, and contract claims against companies for trial.
- May 4, 2026: The parties announce a settlement two weeks before a May 18 trial.
- June 12, 2026: Liman holds she is entitled to reasonable 47.1 fees and denies the extra damages.
- August 26, 2026: He sets the number at $363,245.40 in fees and $44,206.35 in costs.
Lively’s camp has a clean fact on this ledger that the 5 percent figure does not erase. Baldoni’s $400 million case is gone. He was already out of her remaining trial claims as an individual defendant before the settlement. He still writes this check. That is the version of “who won” that does not need a press release.
No Money Changed Hands in May
The May deal ended Lively’s own case without a trial and without a payment on her claims. Wayfarer’s lawyers later told the court she dismissed her three remaining counts “without the Wayfarer Defendants paying a cent of the $300 million in damages she was demanding,” a figure from her original ask as described in that filing. The joint statement said the film was a source of pride, that concerns she raised “deserved to be heard,” and that the parties remain committed to workplaces “free of improprieties and unproductive environments.”
What the settlement did not bury was the 47.1 motion. A May 7 notice of settlement and joint stipulation kept that claim alive, submitted it to Liman, and waived any appeal of the 47.1 ruling. Wednesday’s dollar figure is, by design, the last money in the federal file.
Her lawyers had tried to turn that leftover motion into something larger than costs. After the settlement they said Baldoni and the individual defendants, having waived appeal, faced personal liability for “abusing the legal system to silence and intimidate” her. Freedman answered that the court had already dismissed 10 of 13 of her claims, including every sexual-harassment count, and that she dropped the rest. In his view, they settled because they were going to lose.
Both of those statements can be true at once. The harassment claims never reached a jury. The retaliation theory against the companies never did either. The only judgment that now has a number on it is this fee award, and it is a six-figure number attached to a nine-figure countersuit that failed.
Her Lawyers Called $407,000 Historic
Esra Hudson of Manatt and Michael Gottlieb of Willkie, Lively’s lawyers, told TMZ and Entertainment Weekly that Baldoni and the Wayfarer parties “lost their meritless retaliatory $400 million lawsuit, which two different courts held was designed to stifle public criticism and silence Blake Lively and others.” They called the fee award a first under the California law and said it shows “there are real consequences of bringing retaliatory lawsuits.” They added, “As we have said from day one, Blake Lively’s case was never about money, it was about accountability.”
That last sentence is now sitting next to an $8 million invoice. It is a hard sentence to read without the bill in view. It is also the sentence they needed, because the statute’s heavier tools, treble and punitive damages, were already off the table in June.
They pointed to new filings in the Rebel Wilson and Amanda Ghost fight as proof Lively had “lifted the curtain” on secret online smear campaigns that, they said, “largely target women, and unsurprisingly involve the same players.” Court papers filed in Los Angeles on August 25 include texts in which crisis publicist Melissa Nathan, a Wayfarer defendant in Lively’s case, quoted $110,000 for an “untraceable site.” Ghost’s lawyers say Wilson used some of the same professionals Lively accused of running a campaign against her. Wilson’s lawyer, Allyson Thompson, called the motion one-sided and said Wilson looks forward to trial. That case is not this judgment. It is the industry argument Lively’s team is still trying to win in public after the clerk’s office closed the fee docket.
Freedman’s version is narrower and, on the arithmetic, easier. The court looked at an $8 million-plus demand, he said, and awarded 5 percent. “The ruling is a significant victory for my clients and sends a clear message that, no matter how powerful you may be, the courtroom is not a place to take advantage of the law for your own personal gain.”
The order supports both speeches and fully satisfies neither. Lively leaves with the first 47.1 fee judgment and a finding that Wayfarer’s defamation case fit the statute. Baldoni leaves paying a fraction of the number on her papers, after a settlement that paid her nothing on the harassment and retaliation claims. The louder split online is still that scoreboard. The more durable line in the opinion is smaller: 47.1 is real in federal court, and it is also only as wide as the defamation count a judge is willing to isolate.
Frequently Asked Questions
How much did Blake Lively receive in attorneys’ fees from Justin Baldoni?
The judgment is $363,245.40 in attorneys’ fees and $44,206.35 in costs, a combined $407,451.75. In the June 30 fee papers, Lively’s team said about $4.5 million of the $7.5 million fee ask would have gone to Willkie Farr & Gallagher and about $3 million to Manatt, Phelps & Phillips. Partner Michael Gottlieb disclosed a discounted hourly rate of $2,187, down from his usual $2,795, and 224 hours on the countersuit defense, or about $457,000 of work from him alone, according to the Associated Press account of that filing.
What is California Civil Code Section 47.1?
It is a privilege and fee-shifting rule added by Assembly Bill 933, signed by Gov. Gavin Newsom on October 10, 2023, and effective January 1, 2024. It protects good-faith statements about sexual assault, harassment, or discrimination and, when a defamation suit over those statements fails, lets the speaker recover fees, costs, treble damages, and punitive damages. California was the first state to pass a statute aimed at this kind of retaliatory defamation filing.
Can Blake Lively or Justin Baldoni appeal the fee award?
Not under the deal they signed. The May 7 stipulation says the parties irrevocably waive any appeal of the court’s 47.1 determination. That is why Wednesday’s order is the end of the federal money fight rather than the start of a new one in the Second Circuit.
Who would have been on trial if they had not settled in May?
Not Baldoni as an individual. After the April 2 summary-judgment ruling, the claims still heading toward the May 18 trial were retaliation and contract counts against Wayfarer Studios and It Ends With Us Movie LLC, plus an aiding-and-abetting retaliation claim against The Agency Group PR LLC, the crisis firm Lively accused of helping an online campaign. Baldoni, Jamey Heath, Melissa Nathan, and the other individuals had already been dropped as trial defendants.
Disclaimer: This article is news reporting and analysis of public court orders, filings, and statements in Lively v. Wayfarer Studios LLC. It is for information only and is not legal advice, a prediction of other cases, or a recommendation that anyone file or drop a claim. Readers with a workplace, defamation, or fee-shifting dispute should consult a licensed attorney in the relevant state before acting on anything described here. The dollar figures, docket events, and remaining rights reflect the sources as of August 27, 2026, and later court papers can change them.
The clerk was directed to enter judgment for $363,245.40 in fees and $44,206.35 in costs. The parties already signed away the right to take that number up on appeal.