Giuliani, who is facing charges in Georgia and Arizona and is an unindicted co-conspirator in the federal election interference case brought against Trump by special counsel Jack Smith, had no "good faith basis" to believe the lies he spread about the election, according to an order entered Tuesday. Some of the false statements cited by a New York appeals court were comments Guiliani made during a post-election press conference at Four Seasons Total Landscaping which took place at the same time that some new outlets called the election for Biden.

"These false statements were made to improperly bolster respondent’s narrative that due to widespread voter fraud, victory in the 2020 United States presidential election was stolen from his client," the decision from a New York appeals court read.