# E. Jean Carroll Defamation Verdicts The two jury verdicts in Carroll v. Trump — $5 million in May 2023 and $83.3 million in January 2024, totaling $88.3 million — represent the first time a sitting or former U.S. president was found liable by a jury for sexual abuse and the largest defamation judgment ever imposed on a U.S. president personally. The cases arose from [[Donald Trump]]'s public denials and attacks against E. Jean Carroll after she accused him of raping her in a Bergdorf Goodman department store dressing room in the mid-1990s. The Carroll verdicts occupy a distinct position in the constellation of Trump legal proceedings tracked by the [[Trump Indictments Timeline]]. Unlike the [[NY AG Civil Fraud Judgment]] (a bench trial with corporate defendants) or the [[Stormy Daniels Hush Money Case]] (a criminal prosecution), the Carroll cases were civil jury trials in which ordinary citizens weighed evidence and found [[Donald Trump]] personally liable for sexual abuse and defamation. The jury verdicts carry a democratic legitimacy that bench rulings and plea negotiations do not — and Trump's continued attacks on Carroll after each verdict became the basis for the escalating damages. ## The Accusation and Context In June 2019, [[New York Magazine]] published an excerpt from Carroll's memoir in which she described being sexually assaulted by [[Donald Trump]] in a Bergdorf Goodman dressing room in late 1995 or early 1996. Carroll, then a prominent advice columnist for Elle magazine, alleged that Trump pushed her against a wall, pulled down her tights, and penetrated her. Carroll told two friends contemporaneously; both later testified under oath. The accusation surfaced in the wake of the Access Hollywood tape — the October 2016 recording in which Trump described grabbing women by their genitals — which had itself become a reference point in the [[Trump Family Corruption Ecosystem]] for Trump's pattern of behavior toward women. Carroll was one of more than two dozen women who publicly accused Trump of sexual misconduct, but her allegation was among the most serious and was supported by contemporaneous corroboration. Trump's response was immediate, personal, and escalating. He denied knowing Carroll ("she's not my type"), accused her of fabricating the story to sell books, suggested she was "totally lying," and implied the accusation was politically motivated. These public statements — made while Trump was serving as president — became the basis for the defamation claims. ## Carroll v. Trump I (May 2023) The first trial took place in April–May 2023 in the United States District Court for the Southern District of New York before Judge [[Lewis A. Kaplan]]. Carroll brought claims under the New York Adult Survivors Act (a temporary look-back window that allowed sexual assault survivors to file civil claims regardless of the statute of limitations) and for defamation based on Trump's October 2022 Truth Social post in which he called Carroll's claims "a Hoax and a lie" and described her as a "complete con job." Trump did not attend the trial or testify in person. His videotaped deposition was played for the jury, in which he was shown the Access Hollywood tape and responded, "Historically, that's true with stars" — referring to his statement that celebrities could grab women without consequence. He also mistakenly identified a photo of Carroll as his second wife, [[Ivana Trump]], undermining his claim that Carroll was "not my type." On May 9, 2023, the jury found Trump liable for sexual abuse (but not rape under New York's narrow statutory definition, which requires penile penetration) and for defamation. The jury awarded Carroll $5 million — $2 million in compensatory damages for the sexual abuse and $3 million for the defamation. The [[Department of Justice]] had previously attempted to intervene in an earlier version of the defamation claim, arguing that Trump's denials were made in his official capacity as president and that the United States should be substituted as the defendant — which would have effectively killed the case under the doctrine of sovereign immunity. Judge Kaplan rejected this argument, and the D.C. Circuit Court of Appeals ultimately ruled that Trump's statements were made in his personal capacity, not as part of his presidential duties. This ruling was a significant precedent for the scope of presidential immunity in defamation cases and connects to the broader [[Supreme Court of the United States]] immunity jurisprudence. ## Carroll v. Trump II (January 2024) The second trial addressed Carroll's original defamation claim based on Trump's 2019 statements denying the assault — the statements that predated the Adult Survivors Act window and were governed by standard defamation law. The trial took place in January 2024, again before Judge Kaplan. This trial was, in some respects, a damages-only proceeding. Because the first jury had already found that Trump sexually abused Carroll and defamed her, the second jury's task was to assess damages for the 2019 defamation — with the finding of sexual abuse as established fact. Trump again did not attend for most of the trial, appearing briefly but not testifying. On January 26, 2024, the jury awarded Carroll $83.3 million — $18.3 million in compensatory damages and $65 million in punitive damages. The punitive award was calibrated, the jury instructions indicated, to deter Trump from continuing to make defamatory statements about Carroll. The jury's reasoning was evident in the structure: the large punitive component reflected Trump's pattern of repeating the defamatory statements even after the first verdict, demonstrating that the $5 million award had not deterred him. The combined $88.3 million across both trials made Carroll v. Trump the largest personal defamation judgment against any individual in recent American legal history. ## Deal Mechanics ### The Escalation Dynamic The Carroll cases illustrate a dynamic central to the [[Trump Family Corruption Ecosystem]]: Trump's reflexive public attacks on anyone who challenges him create compounding legal exposure. After the first $5 million verdict, Trump went on CNN and repeated his denials, called Carroll a "whack job," and reiterated that she fabricated the assault. These post-verdict statements became evidence in the second trial supporting the $65 million punitive award. The jury effectively found that Trump's own inability to stop attacking Carroll justified exponentially higher damages. This pattern connects to the [[Stochastic Terrorism]] dynamic tracked elsewhere in the RWKB: Trump's public attacks on Carroll generated harassment from his followers, including death threats that required Carroll to employ security and relocate. The jury heard evidence of this audience-driven harassment when assessing damages. ### Appeal Status Trump appealed both verdicts to the United States Court of Appeals for the Second Circuit. The appeal raises several issues: whether the New York Adult Survivors Act (the look-back window) was constitutional, whether the trial court improperly admitted the Access Hollywood tape and testimony from other women who accused Trump of sexual misconduct, and whether the $83.3 million award was excessive. As of mid-2026, the appeal remains pending before the [[United States Courts of Appeals]]. Trump posted bonds to stay enforcement of both judgments during the appeal. The appeal of the Carroll verdicts is proceeding in parallel with the appeal of the [[NY AG Civil Fraud Judgment]] and the post-conviction proceedings in the [[Stormy Daniels Hush Money Case]], creating a multi-front legal landscape in which Trump faces simultaneous appellate proceedings across civil and criminal dockets. ### Collection Carroll obtained a $91.4 million judgment (including post-judgment interest) and Trump posted a bond to stay collection during the appeal. If the verdicts are upheld, Carroll would collect against the bond and, if necessary, against Trump's personal assets. Unlike the [[Alex Jones Sandy Hook Defamation Judgments]], where the judgment far exceeded the defendant's assets, the Carroll judgment is within the range of Trump's personal resources — though Trump's actual liquid wealth is contested, as the [[Trump NY Civil Fraud Judgment]] bond saga demonstrated. ## Why It Matters for the RWKB The Carroll verdicts are the only cases in which a jury — not a judge, not a prosecutor, not an attorney general — found [[Donald Trump]] personally liable for sexual abuse. The jury finding carries unique weight in the RWKB's tracking of [[Accountability]] and [[Rule of Law]] because it represents the democratic process operating through the civil justice system: twelve ordinary citizens weighed the evidence and concluded that Trump sexually abused Carroll and then lied about it. The cases connect to the RWKB's tracking of [[Disinformation]] as a personal and political weapon. Trump's defamation of Carroll was not just an attack on one woman — it was part of a pattern in which Trump uses public denial and counter-accusation to discredit anyone who threatens his narrative. The same mechanism operates in his attacks on [[Letitia James]], on the prosecutors in the [[Stormy Daniels Hush Money Case]], on the judges in every case against him, and on the media outlets that cover his legal exposure. The Carroll cases are the clearest instance in which this mechanism was subjected to legal scrutiny and found actionable. The punitive damages award in Carroll II — $65 million — was explicitly calibrated to Trump's wealth and his demonstrated willingness to continue the defamatory conduct. The jury concluded that $5 million was not enough to deter him, so they awarded an amount intended to impose real financial pain. This connects to the broader question the RWKB tracks across the [[Trump Indictments Timeline]]: what level of legal consequence is sufficient to alter the behavior of a defendant with vast resources, intense public support, and no apparent capacity for self-restraint? The DOJ intervention attempt — the federal government arguing that Trump's personal attacks on a sexual assault accuser were an official act of the presidency — is a data point in the [[Department of Justice]] and [[Authoritarianism]] tracking. The argument, had it succeeded, would have made the president immune from defamation liability for any statement made while in office, regardless of how personal or malicious. ## Open Questions Will the Second Circuit uphold the verdicts, and if so does it modify the damages? Does the constitutional challenge to the New York Adult Survivors Act succeed, potentially invalidating the sexual abuse finding from Carroll I? Does Trump continue to attack Carroll publicly, and if so does Carroll seek additional damages for post-verdict defamation? How does the presidential immunity doctrine — as expanded by the [[Supreme Court of the United States]] in 2024 — interact with future defamation claims against sitting presidents? ## Connections - Defendant: [[Donald Trump]] - Legal timeline: [[Trump Indictments Timeline]], [[Trump Family Corruption Ecosystem]] - Sister cases: [[Stormy Daniels Hush Money Case]], [[NY AG Civil Fraud Judgment]], [[Trump NY Civil Fraud Judgment]], [[Mar-a-Lago Documents Case]], [[Georgia RICO Case]], [[Jack Smith]] - Trump family: [[Trump Family]], [[Ivana Trump]], [[Trump Organization]] - Financial dimension: [[Trump Media and Technology Group]], [[Truth Social]] - Institutional: [[Department of Justice]], [[Supreme Court of the United States]], [[United States Courts of Appeals]], [[Federal Judges Hub]] - Disinformation as weapon: [[Disinformation]], [[Stochastic Terrorism]], [[Propaganda]] - Legal framework: [[First Amendment]], [[Free Speech]], [[Rule of Law]], [[Democracy]] - AG parallel: [[Letitia James]], [[Arthur Engoron]] - Accountability: [[Oversight and Accountability Hub]], [[Authoritarianism]], [[Judicial Capture]] - Media coverage: [[New York Magazine]], [[Fox News]], [[Media Ecosystem]] ## See Also - [[Donald Trump]] - [[Trump Indictments Timeline]] - [[Stormy Daniels Hush Money Case]] - [[NY AG Civil Fraud Judgment]] - [[Trump Family Corruption Ecosystem]] - [[First Amendment]] - [[Rule of Law]] - [[Department of Justice]]