- Since October, Donald Trump has attended — as a defendant — three Manhattan trials.
- During these trials, judges have repeatedly threatened him with jail or removal from the courtroom.
- His 4 worst judicial rebukes were all prompted by his attacks on women connected to his cases.
Since last fall, Donald Trump has sat at the defense tables of three Manhattan courtrooms. But Trump has shown less-than-ideal table manners.
During all three trials, Trump's judges have been so angered by his outbursts that they threatened to fine him, to remove him from the courtroom, and even to throw him in jail.
Trump earned the worst of these judicial rebukes in the same way, by attacking people connected to his trials in statements he made inside or, in one case, just outside, the courtroom.
Trump's top targets — the people who triggered his four most severe reprimands from the bench — differ widely from each other. They include a law clerk, an advice columnist, a high-school teacher, and a porn star. But they share much in common.
Each made Trump look bad in front of an international trial press corps. Each so riled Trump that he lashed out at them despite the known risk of consequences.
And each of the four is a woman.
"Women are his go-to target, whether it's for sexual assault or if he thinks they're trying to intimidate him," said Debbie Walsh, director of the Center for American Women and Politics.
A lawyer for Trump did not immediately return a request for comment on this story.
"This is his modus operandi," Walsh added.
Trump's top four rebukes
Allison Greenfield was the principal law clerk at Trump's civil fraud trial.
Trump attacked her so persistently last October, including in the hallway outside court, that the judge called Trump up to the witness stand, grilled him about it on the record, then fined him $10,000.
It was a "blatant, dangerous, disobeyal of a judicial order," state Supreme Court Justice Arthur Engoron said of Trump targeting his law clerk during a hallway press gaggle.
Trump risked jail had he continued to attack the clerk, who'd been vocal in reining in defense lawyers during pre-trial hearings.
Greenfield, who received stacks of hate mail and threats after Trump posted her name, photo and social-media contacts on Truth Social, declined to comment on this story.
She will run unopposed for a Manhattan judgeship of her own in November.
E. Jean Carroll
We turn next to E. Jean Carroll, the advice columnist who won more than $90 million in judgments from Trump when he was found liable for sexually abusing and defaming her.
At a federal civil trial in January, Judge Lewis Kaplan threatened to kick Trump out of the courtroom after he repeatedly — and audibly — heckled Carroll as she accused him of defamation during her testimony.
"Mr. Trump has been loudly saying things, including that the witness is lying and noting that she has suddenly got her memory back," defense lawyer Shawn Crowley told Kaplan after jurors were released from the room.
Kaplan threatened jail.
"Mr. Trump, I know you would like me to do that," the judge told Trump.
"You just can't control yourself in this circumstance, apparently," he added.
Carroll declined to comment on this story through her attorney, Roberta Kaplan, who is not related to the judge.
Cowbells herald a third Trump outburst
Fast forward to Trump's hush-money trial, where prosecutors predict they'll wrap their fourth and final week of witness testimony next week, with star witness Michael Cohen set to testify Monday.
Trump is accused of falsifying 34 invoices, checks, and ledger entries in 2017. The cooked books hid a $130,000 hush money payment to porn star Stormy Daniel and illegally influenced the 2016 election, prosecutors allege.
As a criminal defendant, Trump has no choice but to attend this trial. He made his displeasure apparent out of the gate, during jury selection in mid-April.
One prospective juror, a middle-aged high-school teacher, was questioned about videos she had posted online showing people dancing in the streets of her Manhattan neighborhood after Joe Biden's election in 2020.
"It seemed like a celebratory moment in New York City," the school teacher told the judge of uploading the footage to her Facebook account.
Trump lost his cool as he was forced to watch the clips, which included at least one person clanging a cowbell, merrily sounding the death knell for his hopes of reelection.
"He was gesturing and muttering something. He was audible. He was speaking in the direction of the juror. I will not tolerate that," state Supreme Court Justice Juan Merchan complained of Trump to defense lawyer Todd Blanche, his voice raised.
"I will not have any jurors intimidated in this courtroom. I want to make that crystal clear," the judge added.
The woman, whose name was not revealed, was not selected for the jury.
Then there was Stormy Daniels
Trump's most recent severe judicial rebuke came this week, when he began heckling Daniels as she testified against him on Tuesday.
Daniels had just finished telling jurors about playfully swatting Trump "in the butt" with a rolled-up magazine — and about his fascination with the porn business.
"Do you all hate each other?" she testified Trump asked her, describing a two-hour chat in his hotel suite during a 2006 celebrity golf tournament in Lake Tahoe.
"Do you sleep with each other off camera?" she said Trump asked.
Daniels had yet to even bring up her raciest allegations when Merchan called the defense lawyers up to the bench, and, in the presence of prosecutors, let Trump have it.
"I understand that your client is upset at this point, but he is cursing audibly, and he is shaking his head visually, and that's contemptuous," the judge told Trump's lawyers during a break in Daniels' testimony.
"It has the potential to intimidate the witness, and the jury can see that," the judge warned.
"You need to speak to him," he told the defense team. "I won't tolerate that."
The magazine-swatting — Daniels told jurors she was taunting Trump for being boastful of being on the cover — had particularly set the GOP front-runner off.
"One time I noticed when Ms. Daniels was testifying about rolling up the magazine, and presumably smacking your client, and after that point he shook his head and he looked down," the judge said of Trump.
"And later, I think he was looking at you, Mr. Blanche, later when we were talking about The Apprentice. At that point he again uttered a vulgarity."
Why women?
What is it about the thought of a woman publicly opposing him that makes Trump so unable — or unwilling — to restrain himself that he risks getting thrown out of court or thrown into jail?
Does he helplessly lose his temper? Does he lash out intentionally, perhaps thinking it can't hurt his poll numbers, even among women?
Walsh, from the Center for American Women and Politics, thinks the latter's more likely.
"He prides himself on being a strong, macho guy," she said.
"Listen, we know he defended himself for the Access Hollywood tape by saying it was locker-room talk, and boys will be boys," she said.
''But he really walks around thinking that he can grab women because he is who he is," she said.
An honorable mention for Michael Cohen
Trump is barred under an April 1 gag order from making statements attacking jurors, witnesses, and certain trial and prosecution staffers or their families.
Cohen — Trump's one-time corporate and personal lawyer, and now, in the hush-money trial, the top witness against him — has easily been the most frequent target of Trump's online and spoken attacks.
Trump has also been sanctioned for attacking the impartiality of the hush-money trial jury, on which men hold a 7-5 majority.
But despite fining Trump a total of $10,000 for violating his gag order, Merchan has noted that Cohen, who gives as good as he gets, is the one witness least in need of the order's protection.
"As recently as, I believe, Wednesday night, he was on TikTok," Blanche, the defense lawyer, complained to Merchan before court broke for the week on Friday.
"He was wearing a white T-shirt with a picture of President Trump behind bars, wearing an orange jumpsuit, and discussing about how he's now announcing he's running for Congress," the defense lawyer complained of Cohen.
"He has stated on social media that he's going to stop talking a couple of different times, and he doesn't," Blanche added.
Agreeing that Cohen needed to be reined in, Merchan ordered prosecutors to instruct him yet again to stop making public statements about Trump and the case.
Prosecutor Joshua Steinglass told the judge he's already tried to, repeatedly, but would try again.
"Does he go after men, yes," Walsh said of Trump.
"But women hold a special place for him. He clearly feels entitled to exert this kind of power of intimidating and bullying over women," she said.
"He is in some ways like a petulant teenager. He doesn't even understand or respect — 'Hey, I'm in court.'"
Trump may well be playing to his base, meaning "those MAGA men and even some of the MAGA women," Walsh said.
"He is sort of the defender in their minds of white men who are in charge and don't take guff from anybody," she added.
"It's hard to explain the women who are supportive of this kind of behavior, but there are women who will never leave him."
