Robert Trump sued his niece, Mary Trump, seeking to block her from publishing a book that includes critical statements about Donald Trump, who is Robert’s brother and Mary’s uncle. The suit was based on a non-disclosure agreement (NDA) included in the 2000 settlement of litigation over the estate of Robert and Donald Trump’s father. Robert Trump moved for a preliminary injunction against both Mary Trump and the book’s publisher, Simon & Schuster. Public Citizen filed an amicus brief arguing that the NDA should be narrowly construed under the rule that waivers of constitutional rights should be read narrowly and explaining that, by doing so, the court can avoid deciding whether the NDA supports a prior restraint against publication. In a decision issued on July 13, 2020, the court denied the motion for a preliminary injunction.