In a landmark legal decision that has sent shockwaves through the American political and judicial landscape, the United States Court of Appeals for the Second Circuit, on September 8, 2025, upheld a jury verdict ordering President Donald Trump to pay $83.3 million to writer and former advice columnist E. Jean Carroll. The ruling marks the culmination of a contentious legal battle rooted in Carroll’s allegations of sexual assault and defamation, stemming from events she claimed occurred nearly three decades ago. This article delves into the background of the case, the legal proceedings, the arguments presented, the court’s rationale for affirming the verdict, and the broader implications of this high-profile case for both the parties involved and the public at large.
Background of the Case
The origins of this legal saga trace back to 2019, when E. Jean Carroll, a well-known advice columnist for Elle magazine, publicly accused then-President Donald Trump of sexually assaulting her in a Bergdorf Goodman department store dressing room in Manhattan in the mid-1990s. Carroll’s allegations, detailed in a memoir excerpt published in New York magazine, described a harrowing encounter in which Trump allegedly assaulted her after a chance meeting in the upscale department store. The accusation was one of several made against Trump by various women over the years, but Carroll’s case stood out due to her prominence and the subsequent legal actions that followed.
In response to Carroll’s claims, Trump, while serving as president, issued a series of public statements denying the allegations. He asserted that he had never met Carroll, claimed she was fabricating the story for personal and political gain, and suggested that her accusations were motivated by a desire to boost book sales or align with his political opponents. These statements, made through official channels and public platforms, were deemed defamatory by Carroll, who argued that they not only falsely denied her account but also damaged her reputation, subjected her to public ridicule, and caused significant emotional distress.
Carroll initiated a defamation lawsuit in New York state court in November 2019, alleging that Trump’s statements were false and harmful. The case was later moved to federal court after the Department of Justice initially certified that Trump’s statements were made within the scope of his presidential duties, invoking the Westfall Act to substitute the United States as the defendant. However, this certification was withdrawn after further legal scrutiny, allowing the case to proceed against Trump personally.
Parallel Legal Actions and the Role of New York’s Adult Survivors Act
As the defamation case progressed, a significant development occurred in 2022 when New York passed the Adult Survivors Act. This legislation temporarily lifted the statute of limitations for survivors of sexual assault, allowing them to file civil lawsuits for incidents that occurred years prior. Seizing this opportunity, Carroll filed a second lawsuit against Trump in November 2022, accusing him of sexual abuse and additional defamation based on statements he made after leaving office in 2021. In this second case, known as Carroll II, a federal jury in May 2023 found Trump liable for sexual abuse and defamation, awarding Carroll $5 million in damages. This verdict established key findings, including that Trump had sexually abused Carroll and that his denials were defamatory.
The findings in Carroll II had a direct impact on the original defamation case (Carroll I), as the court applied the principle of issue preclusion. This legal doctrine prevented Trump from relitigating facts already established in the second case, such as the truth of Carroll’s assault allegations and the falsity of Trump’s denials. Consequently, when the original defamation case went to trial in January 2024, the proceedings were limited to determining the damages for Trump’s 2019 statements. The jury, after a highly publicized trial, awarded Carroll a staggering $83.3 million, comprising $7.3 million for reputational damage, $11 million for emotional harm, and $65 million in punitive damages intended to deter similar conduct.
Trump’s Appeal and Legal Arguments
Following the January 2024 verdict, Trump moved for a new trial or a reduction of the damages, arguing that the award was excessive and that he was entitled to presidential immunity for statements made during his tenure. He also challenged the court’s application of issue preclusion, the jury instructions, and certain evidentiary rulings. The United States District Court for the Southern District of New York rejected these motions, prompting Trump to appeal to the Second Circuit.
In his appeal, Trump’s legal team raised several key arguments. First, they contended that Trump was protected by absolute presidential immunity, asserting that his statements were part of his official duties as president to address public allegations. They cited the Supreme Court’s decision in Trump v. United States (2024), which expanded the scope of presidential immunity for official acts. Second, they argued that the $83.3 million award was disproportionate and driven by animus against Trump, violating due process. Third, they challenged the use of issue preclusion, claiming it unfairly restricted Trump’s ability to contest the underlying facts. Finally, they alleged errors in the trial’s evidentiary rulings and jury instructions, which they argued prejudiced the outcome.
The Second Circuit’s Ruling
On September 8, 2025, a three-judge panel of the Second Circuit issued a unanimous decision affirming the district court’s judgment in full. The court’s opinion, detailed in Carroll v. Trump, No. 24-644, systematically addressed and rejected each of Trump’s arguments. The ruling is a significant milestone in the case, as it not only upholds the substantial financial penalty but also sets a precedent for holding public figures accountable for defamatory statements.
On the issue of presidential immunity, the court found that Trump had waived this defense by failing to raise it in a timely manner during the district court proceedings. The judges noted that, even if the immunity claim had been properly asserted, the Supreme Court’s Trump v. United States decision did not retroactively alter the conclusion that Trump’s statements were not protected as official acts. The court emphasized that defamatory statements made to discredit a private citizen’s allegations do not inherently fall within the scope of presidential duties, particularly when they serve personal rather than public interests.
Regarding the damages, the Second Circuit found the $83.3 million award to be reasonable and not excessive. The court highlighted the severity of the harm caused to Carroll, including the loss of her professional reputation, ongoing harassment from Trump’s supporters, and the emotional toll of his public attacks. The $65 million in punitive damages, while substantial, was deemed proportionate to Trump’s wealth and the need to deter similar conduct by a figure of his influence. The court also upheld the application of issue preclusion, noting that the Carroll II verdict had conclusively established the falsity of Trump’s statements, and relitigating these issues would be inefficient and unnecessary.
The Second Circuit further dismissed Trump’s claims of erroneous jury instructions and evidentiary rulings, finding no basis for concluding that the trial was unfair. The court’s comprehensive rejection of Trump’s arguments underscores the strength of Carroll’s case and the judiciary’s commitment to upholding the jury’s findings.
Implications of the Ruling
The Second Circuit’s decision has far-reaching implications, both for the parties involved and for broader legal and societal issues. For E. Jean Carroll, the ruling represents a hard-fought victory after years of public scrutiny and personal attacks. The $83.3 million award, while potentially subject to further appeals to the Supreme Court, provides significant financial compensation for the harm she endured and serves as a public vindication of her claims. Carroll’s legal team has expressed satisfaction with the ruling, emphasizing that it holds Trump accountable for his actions and sends a message that no one is above the law.
For Trump, the ruling adds to a series of legal challenges that have defined his post-presidency and his return to the White House in 2025. The $83.3 million judgment, combined with the $5 million from the Carroll II case, places a significant financial burden on the president, though his legal team has indicated he will continue to appeal, potentially to the Supreme Court. Trump’s spokesperson issued a statement decrying the verdict as part of a “political weaponization” of the justice system, framing it as a “witch hunt” aimed at undermining his presidency. However, the court’s rejection of his immunity claims weakens his narrative that these legal battles are solely politically motivated.
The case also has broader implications for defamation law and the accountability of public figures. It reinforces the principle that even the most powerful individuals can be held liable for statements that harm others’ reputations, particularly when those statements are false and malicious. The substantial punitive damages underscore the judiciary’s willingness to impose significant penalties to deter reckless or harmful speech, especially in the era of social media and polarized political discourse.
Public and Political Reactions
The ruling has sparked intense debate across political and media spheres. Supporters of Carroll view the decision as a triumph for survivors of sexual assault and a step toward accountability for powerful men who use their platforms to discredit accusers. Critics of Trump argue that the verdict exposes his pattern of denying allegations while attacking the credibility of those who come forward. Conversely, Trump’s supporters have rallied behind him, echoing his claims that the case is part of a broader effort by political opponents to target him through the courts. Social media platforms, including X, have been abuzz with reactions, ranging from celebrations of Carroll’s victory to accusations of judicial bias against Trump.
The timing of the ruling, coinciding with Trump’s second term as president, adds a layer of complexity. As a sitting president, Trump’s legal battles are likely to remain a focal point of public attention, potentially influencing his administration’s agenda and public perception. The case also raises questions about the intersection of personal conduct, public office, and legal accountability, particularly in the context of presidential immunity.
The Road Ahead
While the Second Circuit’s ruling marks a significant milestone, the legal battle may not be over. Trump has 90 days from the issuance of the court’s mandate to petition the Supreme Court for review, though there is no guarantee the Court will take up the case. The Supreme Court’s conservative majority, including three justices appointed by Trump, could influence the decision to hear the appeal, particularly given the immunity arguments raised. However, the Second Circuit’s thorough reasoning and reliance on procedural grounds (e.g., Trump’s waiver of immunity) may make it challenging for Trump to overturn the verdict.
In the meantime, the question of whether Trump will immediately pay the $83.3 million remains open. Legal experts note that high-profile defendants often delay payment through appeals, potentially posting a bond to cover the judgment while the process unfolds. For Carroll, the financial award is significant, but the emotional and professional toll of the case—compounded by years of public scrutiny—cannot be fully quantified.
Conclusion
The Second Circuit’s affirmation of the $83.3 million defamation verdict against President Donald Trump in favor of E. Jean Carroll is a defining moment in a case that has gripped the nation’s attention. It underscores the power of the judiciary to hold even the most prominent figures accountable for their words and actions, while highlighting the personal courage of individuals like Carroll who challenge powerful adversaries. As the case potentially moves toward a final appeal, its legacy will continue to shape discussions about defamation, accountability, and the intersection of personal allegations with public life. For now, the ruling stands as a testament to the principle that no one, not even a president, is above the law.
