Title is not accurate. A quote of the Judge, "If President Trump ordered or instructed a member of the Proud Boys [to] go off and murder somebody and someone went off and did that, it follows that … would immunize them from liability for that criminal act? In effect, isn't that what your argument is saying?" - Judge Beryl Howell

The Judge is simply questioning the defense's argument and the legal ramifications if its assertions are accepted in court. The Judge says nothing about President Trump's responsibility during Jan 6th one way or the other.