Rudy Giuliani, former mayor of New York City and a key figure in former President Donald Trump’s efforts to dispute the outcome of the 2020 election, filed for bankruptcy on Thursday. The move comes just after a U.S. District Court ordered him to pay $148 million in damages to two former Georgia election workers after they sued him for defamation.

Giuliani’s bankruptcy filing comes in response to financial difficulties caused by looming legal bills related to the 2020 election.

Rudy Giuliani filed for bankruptcy on Thursday, acknowledging severe financial strain exacerbated by his pursuit of Donald Trump false 2020 election claims and a jury’s award of $148 million to two former Georgia election workers he defamed.

The former New York City mayor listed nearly $153 million in existing or potential debts, including almost $1 million in tax liabilities, money he owes lawyers and many millions of dollars in potential legal judgments in lawsuits against him. He estimated he had assets in the range of $1 million to $10 million.

The filing appears to be intended to buy Giuliani enough time to appeal the ruling in the defamation case according to Reuters.

A spokesperson for Giuliani said the bankruptcy filing will give him time to appeal the $148 million penalty and ensure that other creditors are treated fairly.

"No person could have reasonably believed that Mayor Rudy Giuliani would be able to pay such a high punitive amount," spokesperson Ted Goodman said.

U.S. bankruptcy proceedings can enable people and companies to wipe away or reorganize their debts, and Giuliani's filing will likely pause all of the pending lawsuits against him.

However, it may not allow him to duck the money he owes the election workers, as judges have ruled that defamation penalties cannot be discharged if a debtor has engaged in "willful and malicious" conduct.

Before the ruling, Giuliani had been facing severe financial hardships. The former Trump attorney “has at times turned to Trump’s political action committee for help paying his legal bills.”

As indicated above, U.S. bankruptcy law may not necessarily permit the dissolution of debts arising from “willful and malicious injury” to another person. In this case, it does not appear likely that the defamation penalties against Giuliani could be discharged, given the nature of the court’s ruling.

Although almost all debts are discharged when someone files bankruptcy, there’s a small number of types of debts that aren’t discharged. For example, the bankruptcy code excludes from discharge any debts for willful and malicious injuries caused by the debtor. Prior to 1978 the standard for interpreting the phrase “willful and malicious” was whether the debtor had acted with “reckless or knowing disregard,” but passage of the Bankruptcy Reform Act of 1978 overruled that interpretation of the phrase.

The bankruptcy code now requires a showing that the debtor acted both intentionally and maliciously to cause not just the act but also the resulting injury. A creditor who wants to have a debt excluded from the bankruptcy discharge for an injury committed by the debtor must now prove by a preponderance of the evidence that the debtor acted with malicious intent to cause the resulting harm, not just that they acted intentionally in a way that resulted in the harm. Courts have ruled that malice requires more than just reckless behavior by the debtor.

Nevertheless, if this filing gives Giuliani more time to appeal the decision and potentially lower or eliminate the settlement, then it might be the most sensible legal maneuver available to him, especially considering the other pending legal actions against him.