E. Jean Carroll Defamation Verdict: $83.3 Million Jury Award for 'Remarkably Reprehensible' Conduct
Tier 1Upheld on Appeal2022-11-24 to 2025-12-09
Factual Summary
On January 26, 2024, a federal jury in Manhattan awarded E. Jean Carroll $83.3 million in damages after finding that Donald Trump had defamed her by repeatedly denying her allegation that he sexually assaulted her in a Bergdorf Goodman department store dressing room in the mid-1990s and by attacking her character and motives. The verdict, which came in a second trial following an initial jury finding in May 2023, was upheld on appeal in December 2025.
Carroll first publicly accused Trump of sexual assault in a New York magazine excerpt from her memoir in June 2019. Trump responded by calling Carroll a liar, saying she was "not my type," suggesting she fabricated the story to sell books, and accusing her of making up the allegation for political purposes. Carroll filed a defamation lawsuit in November 2019.
In a separate but related trial in May 2023, a jury found Trump liable for sexually abusing Carroll and for defaming her, awarding her $5 million. That verdict established as a matter of civil adjudication that Trump had sexually abused Carroll. The judge in that case, Lewis Kaplan, later clarified that the jury's finding was "substantially" consistent with the definition of rape under common usage.
The second trial, in January 2024, addressed additional defamatory statements Trump made after leaving office. During the trial, Trump continued to attack Carroll publicly, posting on Truth Social and making statements to the press outside the courtroom. He called the case a "con job" and a "hoax" while the jury was deliberating. The jury deliberated for less than three hours before awarding $7.3 million in compensatory damages for emotional harm, $11 million in compensatory damages for reputational harm, and $65 million in punitive damages.
In affirming the verdict, the Second Circuit Court of Appeals noted that "the degree of reprehensibility" of Trump's conduct was "remarkably high, perhaps unprecedented." The appeals court found that Trump's attacks on Carroll spanned at least five years, became "more extreme and frequent as the trial approached," and continued during the trial itself. Trump had publicly stated that he would continue to defame Carroll "a thousand times." The court concluded that the jury's damages awards were "fair and reasonable."
Trump filed a motion for a new trial and subsequently appealed, arguing that the damages were excessive and that his statements were protected opinion. The Second Circuit rejected these arguments and upheld the full $83.3 million verdict.
Primary Sources
1. Jury Verdict, Carroll v. Trump, No. 22-cv-10016 (S.D.N.Y. Jan. 26, 2024)
2. Jury Verdict, Carroll v. Trump, No. 22-cv-10016 (S.D.N.Y. May 9, 2023) (first trial, $5 million)
3. Second Circuit Court of Appeals opinion affirming $83.3 million verdict, Carroll v. Trump, December 2025
4. Order denying motion for new trial, Judge Lewis Kaplan, February 8, 2024
Corroborating Sources
1. NPR: "Jury orders Trump to pay $83 million for defaming columnist E. Jean Carroll," January 26, 2024
2. CNBC: "Trump must pay E. Jean Carroll $83.3 million in defamation trial," January 26, 2024
3. First Amendment Watch: "Appeals Court Upholds E. Jean Carroll's $83.3 Million Defamation Judgment Against President Trump," December 2025
4. Washington Post: "Trump ordered to pay E. Jean Carroll $83.3M in defamation damages trial," January 26, 2024
5. Courthouse News Service: "Jury awards E. Jean Carroll $83.3 million in damages for Donald Trump defamation," January 26, 2024
Counterarguments and Context
Trump maintained that he never met Carroll in the manner she described and that her account was fabricated. He argued that his denials and criticisms of Carroll were protected First Amendment expression and opinion, not actionable defamation. His legal team argued that the $83.3 million verdict was grossly excessive and that the punitive damages were disproportionate to the compensatory damages, violating due process. Trump characterized the lawsuit as politically motivated, noting that Carroll's legal team included attorneys connected to Democratic causes and that the timing of the case was designed to damage his presidential campaign. Some legal commentators noted that the size of the punitive damages award was unusually large for a defamation case and could face further scrutiny. However, two separate juries found against Trump, the trial judge and the appeals court found the damages reasonable, and the appeals court specifically noted that Trump's conduct was "remarkably reprehensible" in part because he continued to attack Carroll during the trial despite knowing that his statements were the subject of the lawsuit. The $65 million punitive damages award reflected the jury's assessment that a smaller amount would not deter Trump, given his wealth and his stated intention to continue defaming Carroll.
Author's Note
This entry is classified as Tier 1 because the case was tried before a jury, resulted in a verdict, and was upheld on appeal. The combined verdicts from both Carroll trials total $88.3 million. The first trial is documented in a separate entry (CIVIL-001). This entry focuses on the second trial and the appellate proceedings because they produced the larger damages award and the appellate court's finding of "remarkably reprehensible" conduct, and because Trump's decision to continue attacking Carroll during the trial itself represents a documented escalation.