Justin Baldoni’s counterclaims in his legal battle with Blake Lively were dismissed—but calling this a clean loss would miss the nuance. In the intricate world of litigation, not all dismissals are equal, and Baldoni’s latest ruling contains strategic advantages that may help him both in court and in public.

Let’s start with what the ruling didn’t do. The judge did not immediately sanction Baldoni or his team. There were no instant financial penalties, no findings (yet) that his counterclaims were brought in bad faith, and no attorney’s fees awarded—at least not in the ruling dismissing his claims. That’s important in a harassment case where aggressive counter-litigation can sometimes backfire severely. By avoiding immediate sanctions, Baldoni kept his ability to argue that he acted in good faith throughout the case.

Another major takeaway is that the court didn’t dismiss his claims with the usual procedural brevity. Instead, it devoted over twenty pages to documenting Baldoni’s version of events. That judicial record—neutral, detailed, and extensive—now exists as part of the case history. Even if the counterclaims didn’t survive, his narrative did. This material can serve not only in court as the harassment case proceeds, but also outside it: in negotiations, media framing, and conversations with industry stakeholders who are closely watching how this plays out.

Importantly, the court granted him leave to amend parts of his claim—specifically those involving breach of contract and tortious interference. This isn’t a free pass, but it gives Baldoni room to refine his arguments and come back with legally sufficient pleadings. Whether he should do that is a strategic decision. Amending those claims may help in settlement leverage, or they may be more distracting than useful depending on where he wants to focus his resources.

Now let’s address the sanctions issue more accurately.

What About Sanctions?

It’s important to clarify: the issue of sanctions is not over. While Baldoni avoided immediate penalties in the motion to dismiss ruling, Blake Lively has a Rule 11 motion pending that seeks monetary sanctions against Baldoni’s co-plaintiffs—Steve Sarowitz, Jamey Heath, Melissa Nathan, Jennifer Abel, and IEWU LLC—and their attorneys.

The sanctions motion alleges the group filed baseless claims of civil extortion, tortious interference, and breach of the implied covenant of good faith, with no factual support and for the improper purpose of harassing Lively through public and media channels. The complaint included a massive “Exhibit A” and was tied to inflammatory media conduct, including statements from Baldoni’s lawyer proposing to live-stream Lively’s testimony at Madison Square Garden. The court has yet to rule on this motion, but if granted, it could carry serious financial and reputational consequences for everyone involved.

In short, Baldoni is not in the clear yet—a sanction ruling could upend the current equilibrium and deepen the narrative of a misuse of the courts for PR warfare.

Rule 11 sanctions motion is not moot, despite the judge granting leave to amend the tortious interference (and breach of contract) claims:

1. Rule 11 Sanctions Target Past Conduct

Rule 11 sanctions are based on whether the original filing (here, the First Amended Complaint or FAC) violated Rule 11 at the time it was filed—not whether it could be fixed in a future version.

As the Supreme Court held in Cooter & Gell v. Hartmarx Corp., 496 U.S. 384 (1990), Rule 11 is designed to deter frivolous filings, and courts are to evaluate whether the legal and factual basis was reasonable at the time of filing. Amending the complaint does not retroactively cure that.

2. Leave to Amend Doesn’t Mean the Original Was Proper

When the judge granted leave to amend, it simply meant:

“You might be able to plead this properly if you supply specific facts.”

That doesn’t mean the original pleading wasn’t sanctionable. Courts often say:

• “You didn’t plead this well, but we’ll give you a chance.”
• Meanwhile, if your original was so groundless that “no competent attorney” would have filed it, you’re still subject to sanctions.

3. Scope of the Sanctions Motion Is Narrower

If you look at Lively’s Rule 11 motion closely (from the PDF you uploaded), it’s not targeting all of Baldoni’s claims, just:

• Civil extortion (Sarowitz, Nathan, Abel, IEWU)
• Tortious interference (all Rule 11 plaintiffs)
• Implied covenant (Sarowitz, Nathan, Abel, Heath)

Even if tortious interference was granted leave to amend, the extortion and implied covenant claims still stand as targets for sanctions.

And critically, Lively limited her sanctions request only to those claims—and only as to the co-plaintiffs and their lawyers—not Baldoni himself.

4. Court Can Still Sanction for Improper Purpose

Rule 11(b)(1) also prohibits filings made for:

• Harassment,
• Delay,
• Driving up litigation costs.

Lively’s team alleges the plaintiffs filed those claims not to win, but to pressure her publicly and in the press (e.g., the MSG deposition stunt, media smears, etc.). Even an otherwise colorable claim can trigger sanctions if filed with an improper purpose.

Strategic Paths Forward

Given the current posture of the case, Baldoni still has viable options:

1. Focus on Defending the Harassment Case
   He now has a detailed judicial summary of his version of events. That record may help during discovery, at trial, or even with jury selection.
2. Use the Court’s Tone to Argue Good Faith
   Although sanctions are pending, the court’s earlier ruling did not condemn his conduct. That ambiguity might help him with industry partners like WME or public audiences.
3. Keep the Option to Amend Narrow Claims
   Breach of contract and interference claims were granted leave to amend. These could be used strategically as leverage, or shelved to focus firepower on the main case.
4. Leverage the Judicial Record in PR Strategy
   While he must tread carefully, Baldoni can point to the court’s detailed engagement with his claims to counteract any media narrative that he was summarily dismissed or frivolous.

What He Should Avoid

1. Claiming Victory Too Loudly
   Overplaying this ruling as a win risks undercutting his defense and could be used by Lively to argue he’s trying to spin the outcome disingenuously.
2. Refiling Weak Claims Just to Retaliate
   Bringing back marginal claims may create new discovery exposure or invite stronger sanctions later.
3. Escalating the Media Fight
   The judge has expressed concern about the PR war around the litigation. A quieter, strategic approach may now serve him better.

The Bottom Line

While Baldoni’s counterclaims were dismissed, he avoided the most immediate dangers—at least for now. The ruling gives him a strategic foothold and a judicial record to build his defense. But with sanctions still looming and the harassment case moving forward, the pressure is far from over.

The real test lies ahead: Can Baldoni take these limited procedural wins and turn them into a credible, robust defense against the explosive allegations that sparked this case?