Jury Awards E. Jean Carroll $83.3 Million in Second Defamation Trial Against Trump

A federal jury in Manhattan awarded E. Jean Carroll $83.3 million in damages against Donald Trump for defamatory statements he made as president in June 2019 denying her sexual assault allegation and attacking her character. The nine-person jury deliberated for less than three hours before returning the verdict on January 26, 2024, in a trial presided over by U.S. District Judge Lewis A. Kaplan. The damages award included $18.3 million in compensatory damages—$11 million for reputational repair, $7.3 million for emotional harm—and a staggering $65 million in punitive damages intended to punish Trump and deter future defamatory conduct. The verdict came just nine months after a different jury had found Trump liable for sexually abusing Carroll and defaming her in 2022 statements, awarding her $5 million, but Trump’s inability to stop publicly attacking Carroll had triggered this second defamation trial focused solely on the amount of damages warranted for his June 2019 statements as president.

This trial operated under unusual constraints because Judge Kaplan had already ruled, based on the earlier verdict, that Trump was collaterally estopped from relitigating whether he had defamed Carroll or sexually assaulted her—those facts were legally established. The only issue for this jury was how much Trump should pay for the defamation he committed through his June 21-24, 2019 statements, including his claim that Carroll’s allegation was “a complete con job,” that “she’s not my type,” and that she was lying to sell books. Carroll’s attorney Roberta Kaplan (no relation to the judge) argued that Trump’s wealth, power, and platform required a damages award large enough to actually get his attention and force him to stop defaming Carroll, noting that the previous $5 million verdict had clearly failed to deter him as he had continued making similar statements including during the current trial.

Trump’s Courtroom Behavior

Trump attended most of the trial over several days, a notable departure from his absence at the first Carroll trial, but his presence proved counterproductive to his defense. During Carroll’s testimony, Trump was observed shaking his head, making audible comments, and displaying body language that suggested contempt, prompting Judge Kaplan to warn Trump’s attorneys multiple times to control their client. On January 25, Trump briefly testified but was strictly limited by Judge Kaplan to a narrow scope after Trump violated pre-trial rulings by attempting to relitigate the sexual abuse allegation. Trump’s testimony lasted only about three minutes before Judge Kaplan cut him off, with Trump managing only to state “I never met this woman” and deny the assault before the judge shut down his attempts to make broader statements.

Most dramatically, during closing arguments on January 26, Trump abruptly stormed out of the courtroom as Carroll’s attorney Roberta Kaplan told the jury that Trump was “a liar” who thinks “the rules don’t apply to him.” Judge Kaplan interrupted the closing argument to note for the record: “The record will reflect that Mr. Trump just rose and walked out of the courtroom.” Trump returned for his own attorney’s closing arguments but left the courthouse approximately 30 minutes before the jury returned its verdict, ensuring he was not present when the $83.3 million award was announced. Trump’s courtroom behavior—the visible contempt, the walkout, the inability to control himself even when constrained by the judge—likely contributed to the jury’s decision to impose such substantial punitive damages, as it demonstrated in real time that Trump had no intention of stopping his defamatory attacks on Carroll.

The Damages Evidence and Verdict

Carroll’s legal team presented evidence of the extensive harassment, death threats, and professional damage she suffered from Trump’s defamatory statements, which had mobilized his supporters to attack her online and in person. Carroll testified about receiving rape and death threats, being told she should be “dragged down the street and raped,” and experiencing severe emotional distress including anxiety, depression, and fear for her safety. Expert witnesses testified about the monetary value of repairing Carroll’s reputation and compensating her for emotional harm. Significantly, Carroll’s attorneys argued that Trump’s massive wealth—estimated at the time in the billions—and his continued defamatory statements even during the trial necessitated a damages award large enough to actually impact him financially and send an unmistakable message that continued defamation would be prohibitively expensive.

The jury’s $65 million punitive damages award was more than three times the $18.3 million in compensatory damages, reflecting the jury’s conclusion that Trump’s conduct warranted substantial punishment. Under federal standards, punitive damages should not exceed a single-digit ratio to compensatory damages, but the jury’s 3.5:1 ratio fell well within constitutional bounds and suggested jurors believed Trump’s wealth, power, and demonstrated unwillingness to stop defaming Carroll required an exceptional deterrent. The total $83.3 million award was sixteen times larger than the first Carroll verdict, indicating the jury’s belief that only a truly massive financial penalty would get Trump’s attention.

Significance

The $83.3 million verdict represented one of the largest defamation damages awards in American history and created the remarkable situation of a leading presidential candidate owing nearly $90 million to a woman who accused him of sexual assault. The award brought Trump’s total Carroll-related liability to $88.3 million, with both verdicts establishing in federal court that Trump had raped Carroll (under common definitions) and then compounded the harm by repeatedly lying about it and attacking her character. The size of the award reflected not just the harm Trump caused Carroll, but the jury’s assessment that Trump’s wealth, platform, and demonstrated pattern of ignoring legal judgments required an unprecedented financial punishment.

The verdict validated Carroll’s decision to continue pursuing Trump in court rather than accepting the first $5 million verdict as sufficient, demonstrating that Trump’s inability to control his defamatory impulses created escalating legal liability. The case also established important legal precedents about collateral estoppel in defamation cases—once liability is established, subsequent trials can focus solely on damages for continued defamatory conduct about the same underlying facts. This principle could enable other Trump defamation victims to more easily obtain damages for ongoing attacks.

Trump’s behavior during the trial—his courtroom outbursts, his truncated testimony, and his dramatic walkout—provided real-time evidence supporting Carroll’s argument that he had no respect for the legal process and no intention of stopping his attacks. The jury appeared to take this demonstration seriously in calculating punitive damages designed to actually deter future misconduct. The verdict came as Trump was campaigning for president in 2024, creating the extraordinary political situation of a major party’s presumptive nominee owing massive damages for defaming a woman a jury had found he raped.

Most significantly, the escalating verdicts—from $5 million to $83.3 million—demonstrated the consequences of Trump’s psychological inability to exercise restraint or accept legal accountability. His compulsive need to attack Carroll, even after being found liable, transformed what could have been a single adverse verdict into nearly $90 million in damages and established a legal record of both sexual abuse and repeated defamation that would follow him throughout the 2024 campaign and beyond. The verdict proved that even Trump’s wealth had limits when confronted with the compound interest of repeated defamatory conduct, and it provided a powerful example of how the civil justice system could hold even the most powerful political figures financially accountable when criminal prosecution was unavailable.