A federal appeals court on Monday refused to overturn an $83.3 million jury verdict against President Donald Trump for defaming writer E. Jean Carroll, rejecting his argument that presidential immunity shielded him from liability.
The 2nd U.S. Circuit Court of Appeals in Manhattan issued a unanimous decision, with a three-judge panel saying, “The jury’s duly rendered damages awards were reasonable in light of the extraordinary and egregious facts of this case.” The award includes $18.3 million for emotional and reputational harm and $65 million in punitive damages. The ruling leaves in place a separate $5 million verdict that a different jury returned in May 2023 and that the appeals court upheld on June 13.
Carroll, 81, a former Elle magazine columnist, sued after Trump publicly denied her allegation that he sexually assaulted her in a Bergdorf Goodman department store dressing room around 1996. Carroll first made the accusation in 2019; Trump told a reporter at that time that Carroll was “not my type” and suggested she had fabricated the account to sell a memoir. He reiterated critical comments on his social media platform in October 2022, statements that were central to the earlier defamation finding.
In his most recent appeal, Trump argued that a U.S. Supreme Court decision in July 2024 that significantly expanded presidential immunity in criminal cases should bar Carroll’s civil claims. He contended his statements about Carroll in 2019 were made in his official capacity and that denying immunity could harm the independence of the executive branch. Trump also argued that U.S. District Judge Lewis Kaplan, who presided over the trials, erred in excluding portions of his testimony, including a statement that he spoke to defend himself, his family and “the presidency.”
The appeals court rejected those arguments and affirmed the jury’s findings and awards. The panel did not accept that the Supreme Court’s 2024 ruling provided a shield in this civil defamation case, and it found the damages awards supported by the record.
Neither the White House nor Trump’s personal lawyers in the case immediately responded to requests for comment after the ruling.
Carroll’s lawsuit has produced a series of legal decisions. In the 2023 trial that led to the separate $5 million award, jurors found Trump liable for sexually abusing Carroll but did not find that he had committed rape under New York law. The $83.3 million award followed a later trial focused on defamation stemming from Trump’s comments denying her account and attacking her credibility.
Carroll has written about her legal battles in a recently published memoir, Not My Type: One Woman vs. a President. The litigation and the appeals court rulings together underscore continuing legal consequences for the president stemming from long-running disputes with Carroll.
The 2nd Circuit’s decision is likely to be notable for how appellate courts treat the scope of presidential immunity as defined by the Supreme Court’s 2024 decision. The appeals court here distinguished that precedent’s reach in the context of civil defamation litigation, while upholding the jury’s conclusions about the harm caused by Trump’s public statements.
The case’s procedural posture now leaves the $83.3 million judgment intact. Any further legal challenges would require additional filings; there was no immediate indication from Carroll’s legal team about collection efforts following the appeals court ruling.
The litigation involving Carroll has been one of several legal matters confronting Trump, whose public statements about accusers and others have prompted multiple civil suits over the past several years. The appeals court opinion emphasized the fact-finding role of juries and the reasonableness of the damages they assessed in this dispute.
