Federal Appeals Court Upholds $5 Million Carroll Verdict Against Trump

A three-judge panel of the U.S. Court of Appeals for the Second Circuit unanimously upheld the $5 million jury verdict finding Donald Trump liable for sexually abusing and defaming E. Jean Carroll, rejecting all of Trump’s arguments that trial errors warranted overturning the May 2023 verdict or ordering a new trial. The December 30, 2024 decision came just weeks before Trump was scheduled to be inaugurated as president for a second term, ensuring that he would begin his presidency as the only U.S. president found civilly liable for sexual abuse. The appeals court’s ruling comprehensively addressed and dismissed Trump’s numerous appellate claims, including arguments that U.S. District Judge Lewis A. Kaplan had improperly allowed testimony from two other women who accused Trump of sexual assault, that the jury instructions were flawed, that evidentiary rulings were erroneous, and that the damages award was excessive.

The Second Circuit panel—composed of Judges Denny Chin, Susan L. Carney, and Myrna Pérez—issued a detailed opinion concluding that “Mr. Trump has not demonstrated that the district court erred in any of the challenged rulings” and that “he has not carried his burden to show that any claimed error or combination of claimed errors affected his substantial rights as required to warrant a new trial.” The court specifically upheld Judge Kaplan’s decision to allow testimony from Jessica Leeds and Natasha Stoynoff, two women who testified about their own allegations of sexual assault by Trump, finding this evidence admissible under Federal Rule of Evidence 415 which permits propensity evidence in sexual assault cases. The appeals court rejected Trump’s argument that this testimony was unfairly prejudicial, noting that the similarities between the incidents—Trump’s use of positions of power, sudden physical force, and the locations of the assaults—made the evidence probative of his propensity to commit sexual assault.

Rejection of Trump’s Legal Arguments

The appeals court systematically dismantled each of Trump’s appellate arguments. Trump had claimed Judge Kaplan improperly excluded certain defense evidence, but the Second Circuit found these evidentiary rulings were within the trial judge’s discretion and did not deprive Trump of a fair trial. Trump argued the jury instructions incorrectly defined sexual abuse and failed to properly explain burden of proof, but the appeals court found the instructions were legally accurate and appropriately conveyed the law. Trump contended the $5 million damages award was excessive and not supported by evidence, but the Second Circuit concluded the award was reasonable given Carroll’s testimony about harassment, death threats, and reputational damage she suffered after Trump’s defamatory statements.

Significantly, the appeals court rejected Trump’s argument that Judge Kaplan was biased against him, finding no evidence that the judge’s management of the contentious trial reflected anything other than appropriate judicial control of the proceedings. The court also dismissed Trump’s claim that his statements about Carroll were protected opinion rather than defamatory assertions of fact, noting that Trump’s categorical denials that the assault “never happened” and that Carroll was lying to sell books were statements of fact that the jury found to be false and defamatory. The comprehensive nature of the Second Circuit’s rejection of Trump’s arguments—addressing and dismissing every claim of trial error—left Trump with limited options for further appeal.

Political and Legal Timing

The December 30, 2024 timing of the decision was politically significant because it came during the transition period between Trump’s election victory in November 2024 and his scheduled inauguration on January 20, 2025. The ruling ensured that Trump would be sworn in as president while owing Carroll $5 million (plus the separate $83.3 million from the second defamation verdict), with both verdicts now affirmed by a federal appeals court. The decision foreclosed Trump’s hope that the appeals court might overturn the verdict before he assumed office, eliminating any possibility that he could enter his second term without the civil liability for sexual abuse hanging over him.

The appeals court’s decision also came amid Trump’s transition planning and cabinet appointments, creating an awkward juxtaposition: while Trump was preparing to return to the presidency with broad claims about restoring law and order, a federal appeals court was affirming findings that he had sexually abused a woman and then lied about it. The ruling reinforced that Trump’s legal troubles would continue into his second term, with the Carroll verdicts representing established legal facts that could not be dismissed as partisan persecution or procedural irregularities—the findings had now been reviewed and affirmed by federal appellate judges who found no trial errors warranting reversal.

Significance

The Second Circuit’s affirmation of the $5 million verdict eliminated any legal ambiguity about whether Trump had sexually abused Carroll, as the verdict had now survived the scrutiny of appellate review. The decision validated Judge Kaplan’s trial management, the jury’s credibility determinations, and the evidentiary foundation for finding Trump liable. By comprehensively rejecting all of Trump’s appellate arguments, the Second Circuit sent a clear message that the trial had been conducted fairly and that Trump’s conviction was based on solid evidence properly evaluated by a jury.

The ruling meant that calling Trump a sexual abuser was no longer just a jury finding from a single trial—it was an appellate-court-affirmed legal fact. This distinction mattered because it foreclosed arguments that the verdict might be overturned on appeal due to trial errors, and it established the sexual abuse finding as settled law unless the Supreme Court intervened. The decision also validated the testimony of Trump’s other accusers (Leeds and Stoynoff) as relevant evidence in sexual assault cases, potentially encouraging other survivors to come forward and creating precedent for using pattern evidence in civil sexual assault litigation.

Trump’s remaining legal option was to petition the Supreme Court for review, but the Court accepts only a small fraction of appeals and typically requires some significant legal question or circuit split to warrant review. The Second Circuit’s thorough analysis of Trump’s claims made it unlikely the Supreme Court would find grounds for reversal, especially given that most of Trump’s arguments involved fact-intensive challenges to evidentiary rulings that appellate courts typically defer to trial judges on. The affirmation of the verdict thus effectively finalized the legal finding that Trump sexually abused Carroll, establishing this as a permanent part of his historical record.

Most significantly, the decision meant Trump would begin his second presidency with federal court findings—now affirmed on appeal—that he committed sexual violence and then defamed his victim. This created unprecedented territory for American democracy: a president with judicial findings of sexual abuse and defamation, owing nearly $90 million to his victim across two separate verdicts. The appeals court’s comprehensive rejection of Trump’s claims eliminated any credible argument that the verdicts resulted from a flawed process, instead establishing that Trump’s liability was determined through fair proceedings that withstood appellate scrutiny. The ruling reinforced that even the presidency could not shield Trump from legal accountability for sexual abuse and defamation, and that the federal courts would continue to enforce civil judgments against him regardless of his political status.