A federal appeals court upheld Monday the $83.3 million judgment against President Donald Trump for defaming writer E. Jean Carroll, rejecting his claims of presidential immunity in a unanimous decision that maintains one of the largest defamation awards in recent legal history.
The 2nd Circuit Court of Appeals in Manhattan declared the jury award “reasonable” given trial evidence while dismissing Trump’s argument that his 2019 statements denying Carroll’s sexual assault accusations were protected official acts during his presidency.
The court noted Trump’s “repeated social media attacks and public statements against the longtime advice columnist after she accused him of sexual assault” contributed to a pattern of harassment that justified substantial damages. Carroll accused Trump of defaming her in statements denying her accusation that he raped her decades earlier in a New York City department store.
Trump’s legal team argued his denials constituted official presidential communications protected under executive immunity, claiming the statements emerged through White House channels as part of his official duties. The appellate panel rejected these arguments, finding the comments were personal responses unrelated to presidential responsibilities.
The massive judgment stemmed from a January 2024 civil trial where jurors found Trump liable for disparaging Carroll following her public accusations of sexual assault at a Manhattan Bergdorf Goodman in the mid-1990s. The award included $18 million in compensatory damages and $65 million in punitive damages.
Trial evidence showed Trump’s denials triggered widespread online harassment against Carroll, a former Elle magazine columnist who testified about receiving thousands of threatening messages. The court documented how Trump’s statements, viewed by millions, unleashed “instant and continuous” attacks including hundreds of death threats.
Carroll filed two separate lawsuits against Trump, with the first case addressing defamatory statements made while he was president, leading to the $83 million verdict currently under appeal. A second case addressed post-presidency comments, resulting in a separate $5 million judgment after jurors found Trump liable for sexual abuse and defamation.
The appeals court emphasized the “unique and egregious facts” surrounding Trump’s public denials, which included claims he had “never met” Carroll and dismissing her accusations as a “hoax.” These statements continued after Carroll filed her initial lawsuit, contributing to the substantial damage award.
Carroll’s legal team successfully argued Trump’s responses represented personal attacks rather than presidential duties, distinguishing them from official communications that might receive executive privilege protection. The court agreed, finding no legitimate governmental interest in Trump’s specific denials and characterizations.
The ruling comes as Trump serves his second presidential term, creating ongoing complications between his official responsibilities and personal legal obligations. The judgment represents one of several civil cases continuing despite his return to the presidency.
Trump’s attorneys indicated plans to seek Supreme Court review of the decision, though the high court typically accepts few civil defamation cases for consideration. Legal experts suggest the presidential immunity arguments face significant obstacles given the personal nature of the disputed statements.
The case highlights ongoing tensions between presidential powers and civil accountability, particularly regarding statements presidents make about private citizens during public controversies. Courts have generally limited executive immunity to actions directly related to official duties rather than personal disputes.
Carroll’s victory represents a significant legal precedent for defamation cases involving public officials, demonstrating that high-profile defendants cannot escape liability through claims of official capacity when making personal attacks against accusers.
The civil jury ordered Trump to pay the substantial damages last year after finding his repeated denials caused measurable harm to Carroll’s reputation and personal safety through the harassment campaign his statements generated.
The appeals court decision reinforces that elected officials, including presidents, remain subject to civil liability for personal conduct that harms private citizens, regardless of their public position or claims of official authority.
Trump faces additional legal challenges across multiple jurisdictions, though this case represents one of the largest financial judgments against him personally. The ruling establishes important boundaries regarding executive immunity claims in civil defamation contexts.
