A federal appeals court has upheld the $83 million defamation judgment against President Donald J. Trump in the high-profile case brought by writer E. Jean Carroll, marking another decisive legal setback for the president.
In its ruling, the 2nd U.S. Circuit Court of Appeals rejected Trump’s arguments that presidential immunity shielded him from liability for statements he made while in office. The three-judge panel concluded that Trump failed to present any grounds warranting reconsideration of earlier rulings on immunity and affirmed that the damages awarded by the jury were “fair and reasonable.”
“Trump has failed to identify any grounds that would warrant reconsidering our prior holding on presidential immunity. We also conclude that the district court did not err in any of the challenged rulings and that the jury’s damages awards are fair and reasonable,” the opinion stated.
The appellate court stressed the seriousness of Trump’s conduct, calling the degree of reprehensibility “remarkably high, perhaps unprecedented.” It highlighted the jury’s rationale for imposing $65 million in punitive damages, which aimed not only to compensate Carroll but also to deter future defamation.
Carroll’s attorneys maintained that Trump’s statements — in which he labeled Carroll’s sexual assault allegations a “hoax” and a “con job” — were personal in nature, not part of his presidential duties. Trump’s legal team countered that remarks issued through the White House press office fell within the “outer perimeter” of presidential responsibilities. The appeals court rejected that defense, noting that the defamation involved quintessentially personal conduct unrelated to official duties.
The judgment stems from Carroll’s first defamation lawsuit, filed in 2019 after Trump publicly denied her claims that he sexually assaulted her in a Manhattan department store in the 1990s. In January 2023, a New York jury awarded Carroll $83.3 million — $11 million for reputational harm, $7.3 million for emotional distress and other damages, and $65 million in punitive damages. The amount continues to grow under New York’s 9% annual interest rate on civil judgments.
Carroll has also prevailed in a second lawsuit, filed under New York’s Adult Survivors Act, which opened a one-year window for adult victims of sexual offenses to bring civil claims.
In May 2023, a jury found Trump liable for sexually abusing and defaming Carroll, awarding her an additional $5 million. The 2nd Circuit previously upheld that verdict as well, though Trump has appealed it to the Supreme Court.
Carroll’s legal team, led by attorney Roberta Kaplan, praised the latest decision as a significant reaffirmation of accountability.
“Even the richest and most powerful can be held responsible under our legal system,” Kaplan said following the ruling.
For Trump, who faces multiple civil and criminal proceedings across jurisdictions, the affirmation of this judgment underscores the narrowing legal options available to challenge the Carroll verdicts.
His attorneys have argued that the outcome represents a miscarriage of justice and threatens the presidency, but courts so far have disagreed.
With interest accruing and the appeals process nearing its conclusion, Trump’s financial exposure in the Carroll cases may exceed $90 million. The ruling also solidifies a key legal precedent: that presidential immunity does not extend to defamatory remarks tied to personal conduct, even when made during a president’s time in office.
