A federal appeals court in Manhattan on Monday rejected U.S. President Donald Trump's effort to overturn an $83.3 million jury award to writer E. Jean Carroll, affirming that his 2019 comments denying her rape allegation were defamatory.
The Second U.S. Circuit Court of Appeals ruled against Trump's arguments that he was entitled to presidential immunity and that the verdict was excessive. Trump "has failed to identify any grounds that would warrant reconsidering our prior holding on presidential immunity," the three-judge panel wrote.
The January 2024 jury award included $18.3 million for reputational and emotional harm and $65 million in punitive damages. Carroll, 81, a former Elle magazine columnist, alleged that Trump sexually assaulted her in a Bergdorf Goodman department store dressing room in the mid-1990s. Trump denied the allegation in 2019, saying Carroll was "not my type" and that she fabricated the story to sell books.
Trump argued that his remarks about Carroll were made in his official capacity as president and that failure to extend immunity could undermine the independence of the executive branch. He also pointed to the Supreme Court's July 2024 decision granting broad criminal immunity to presidents as grounds for appeal. The panel dismissed that reasoning, finding no connection to civil liability.
The ruling follows a June 2024 appellate decision upholding a separate $5 million jury verdict against Trump stemming from a 2022 Truth Social post in which he repeated his denials. That jury also found him liable for sexual abuse but not rape.
Carroll published a memoir in June titled Not My Type: One Woman vs. a President, chronicling her legal fight with Trump. In addition to his immunity arguments, Trump claimed U.S. District Judge Lewis Kaplan erred by excluding testimony in which he said his remarks were intended to defend his family and the presidency. The appellate court found no errors in the lower court proceedings and said the damages were "fair and reasonable."
