Lead
A federal appeals panel on September 8, 2025, declined to set aside an $83.3 million jury award against former President Donald Trump for defaming writer E. Jean Carroll when he denied her rape allegation. The 2nd U.S. Circuit Court of Appeals in Manhattan rejected Trumps presidential immunity claim and upheld the size of the award as reasonable given the record. The unanimous three-judge panel found Trumps repeated public attacks on Carroll became more extreme as litigation approached. The decision leaves intact a separate May 2023 jury award of $5 million against Trump for sexual abuse and defamation.
Key Takeaways
- The 2nd U.S. Circuit on Sept 8, 2025, refused to overturn a $83.3 million civil verdict against Donald Trump for defaming E. Jean Carroll.
- The $83.3 million award comprises $18.3 million for emotional and reputational harm and $65 million in punitive damages.
- The court rejected Trumps claim that a July 2024 Supreme Court ruling on presidential immunity shields him from civil liability in Carrolls case.
- A separate May 2023 jury previously found Trump liable for sexual abuse and defamation and awarded Carroll $5 million; that verdict was upheld on appeal in June 2024.
- The appeals panel described Trumps conduct as showing a high degree of reprehensibility, citing repeated and escalating public attacks over at least five years.
- Trump, 79, continues to appeal multiple legal setbacks, while Carroll, 81, has published a memoir about the litigation and seeks final resolution of the appellate process.
Background
Carroll accused Trump of attacking her in a Bergdorf Goodman dressing room in about 1996. She went public in June 2019 with the allegation and says Trump subsequently damaged her reputation by denying the claim and mocking her on national media and social platforms. In May 2023, a Manhattan jury found Trump liable for sexual abuse and defamation and awarded Carroll $5 million; that decision was affirmed by an appeals court in June 2024.
Following the 2019 exchanges, Trump repeatedly commented about Carroll, including a June 2019 remark that she was not his type and an October 2022 social media post that the jury later found defamatory. Carroll pursued a separate civil suit that resulted in the combined $83.3 million award for the January 2024 verdict that was the subject of the Sept 8, 2025 appeals decision. The litigation unfolded against a backdrop of multiple legal actions involving Trump after he left the presidency in 2021.
Main Event
On Sept 8, 2025, the 2nd U.S. Circuit published a unanimous, unsigned opinion declining to set aside the $83.3 million verdict. The panel said the district court properly excluded an answer in which Trump had sought to frame his comments as defending the presidency, finding that response implied Carrolls accusations were false and was therefore not admissible. The appeals court emphasized the long-running and public nature of Trumps attacks on Carroll as justification for a substantial punitive award.
The panel quoted the district court in describing the degree of reprehensibility as remarkably high and perhaps unprecedented, citing malice, deceit, and severe emotional injury sustained by Carroll. The court found the punitive component of $65 million reasonable in light of those findings and the pattern of conduct over at least a five-year period. The opinion therefore left intact both the overall award and the district court decisions that shaped the trial record.
Trump had argued that a July 2024 U.S. Supreme Court decision that recognized broad criminal immunity for certain official acts should bar Carrolls civil claim. The appeals court rejected that extension, saying the record did not support treating Trumps statements about Carroll as protected presidential speech in the circumstances of this case. Following the ruling, Trumps lawyers reiterated that they plan to continue appeals, framing the litigation as politically motivated.
Analysis & Implications
The appeals ruling tightens the boundary between presidential speech and defamatory conduct by signaling that public office does not give blanket protection for repeated, targeted attacks on private citizens. While the Supreme Court decision in July 2024 narrowed criminal exposure for some official acts, the 2nd Circuit here drew a contrast between policy-protective statements and sustained personal denigration of an accuser. Legal scholars will watch whether other circuits adopt a similar line between official communications and personal statements outside ordinary duties.
Financially, affirming a $65 million punitive component raises questions about collectability and enforcement across jurisdictions. Plaintiffs with large civil awards often face protracted collection battles, and Trump has appealed other monetary judgments successfully in part; state and federal enforcement mechanisms vary, and some remedies can be stayed while appeals proceed. The practical impact on Trumps finances depends on forthcoming appellate filings and any bond or stay orders the courts may impose.
Politically, the ruling is unlikely to change the calculus for voters already aligned with or opposed to Trump, but it may shape messaging in a charged election environment where legal narratives are weaponized on both sides. For future claimants, the decision could be read as affirming that repeated public attacks, particularly with demonstrable malice, can support significant punitive damages even against high-profile defendants. Courts nationwide will consider how to apply the balancing tests the 2nd Circuit used when assessing reprehensibility and punitive proportionality.
Comparison & Data
| Date | Verdict | Amount | Notes |
|---|---|---|---|
| May 2023 | Jury found liable for sexual abuse and defamation | $5,000,000 | Affirmed on appeal in June 2024 |
| January 2024 | Civil verdict for defamation | $83,300,000 | $18.3M compensatory, $65M punitive; appeal denied Sept 8, 2025 |
The table summarizes the two principal jury findings relating to Carrolls claims. The larger January 2024 award reflects statutory and common-law factors courts consider when imposing punitive damages, including reprehensibility and the need for deterrence. Observers note that punitive awards of this magnitude often face proportionality challenges, but appellate courts will overturn only where the award is constitutionally excessive or unsupported by facts.
Reactions & Quotes
Legal teams for both sides reacted quickly after the 2nd Circuit ruling, reiterating positions they have used throughout the litigation and signaling continued appellate activity.
President Trump will keep winning against Liberal Lawfare, as he is focusing on his mission to Make America Great Again.
Statement, Trump legal team
The statement from Trumps lawyers framed the decision as another step in ongoing appeals and presented the litigation as politically motivated. It does not address the appeals courts legal reasoning on reprehensibility or the specifics of the punitive award and instead reiterates a broader campaign narrative.
We look forward to an end to the appellate process so that justice will finally be done.
Roberta Kaplan, Carroll attorney
Carrolls counsel described the ruling as a step toward final enforcement and closure for her client. Kaplan has repeatedly emphasized the emotional and reputational harms the courts found, and said the defense of the appellate process is aimed at securing enforceable remedies for Carroll.
The record supports the district court’s conclusion that the degree of reprehensibility here was remarkably high.
2nd U.S. Circuit Court of Appeals, unsigned opinion
The appeals opinion itself highlighted the pattern and tone of Trumps conduct as central to the punitive calculation. That phrasing will likely be cited in future briefs addressing when public statements become actionable as malicious personal attacks rather than protected commentary.
Unconfirmed
- It is not yet confirmed whether the Trump legal team will seek immediate Supreme Court review; an application to the high court has not been filed as of this writing.
- The timeline and mechanism for enforcing the $83.3 million judgment, including whether a stay or bond will be posted during further appeals, remain uncertain pending future filings and court orders.
Bottom Line
The 2nd Circuit ruling on Sept 8, 2025, reinforces that high public office does not automatically shield repeated, personal attacks from civil liability, and it sustains a substantial punitive award based on a documented pattern of conduct. While Trump continues to pursue appeals across multiple cases, the decision narrows the immunity argument when statements are treated as personal denigration rather than core presidential duties.
For victims of publicized alleged misconduct, the ruling signals that courts may sustain significant damages where malice and ongoing reputational harm are shown. Practically, the road to collecting large civil awards remains complex, and the ruling is likely to prompt further appellate litigation about enforcement, proportionality, and the scope of official-immunity protections.
Sources
- Reuters (news report)
- 2nd U.S. Circuit Court of Appeals (court opinion and docket)
- U.S. Supreme Court (July 2024 opinion on immunity, official government source)
- What Do We Need Men For? and Not My Type (Carroll memoirs, publisher information)