On September 8, 2025, a federal appeals court delivered a resounding affirmation of writer E. Jean Carroll’s legal victory over former President Donald Trump, upholding an $83.3 million defamation judgment that has become a flashpoint in the ongoing debate over accountability, presidential power, and the treatment of sexual assault survivors in the public eye. The decision, handed down by the 2nd U.S. Circuit Court of Appeals, rejected Trump’s arguments for immunity and left intact one of the largest personal defamation awards in U.S. history.
The panel of Judges Denny Chin, Sarah A.L. Merriam, and Myrna Pérez Kahn found that Trump’s repeated public attacks on Carroll—both during and after his presidency—warranted the jury’s award of $18.3 million in compensatory damages and $65 million in punitive damages. According to Fox News, the court declared, “We conclude that Trump has failed to identify any grounds that would warrant reconsidering our prior holding on presidential immunity. We also conclude that the district court did not err in any of the challenged rulings and that the jury’s damages awards are fair and reasonable.”
The case traces back to Carroll’s 2019 public accusation that Trump sexually assaulted her in a department store dressing room in the 1990s—a claim Trump has consistently denied, at times calling Carroll a liar and insisting she was “not my type.” These denials, broadcast to an audience of roughly 86 to 104 million people, sparked a torrent of online abuse and threats directed at Carroll, as documented in court filings and recounted by the appeals panel. The judges wrote that “Trump acted with, at a minimum, reckless disregard for the truth,” and emphasized the “remarkably high, perhaps unprecedented” degree of reprehensibility in his conduct.
Carroll’s legal saga against Trump has unfolded across two lawsuits. The first, resulting in the $83 million award, centered on defamatory statements Trump made while president. The second, made possible by a temporary New York law that revived expired sexual assault claims, led to a $5 million verdict in May 2023 after a jury found Trump liable for sexual abuse and defamation. As Law Commentary detailed, the appeals court previously upheld that $5 million verdict earlier in 2025.
Trump’s legal team had sought to overturn the $83.3 million judgment by invoking the Supreme Court’s 2024 ruling on presidential immunity, arguing that his statements about Carroll were made within the scope of his official duties. The appeals court was unmoved. Not only did it find the immunity defense inapplicable to this civil defamation case, it also ruled that Trump had waived the argument by not raising it earlier. The panel noted that Trump’s efforts to substitute the United States as the defendant under the Westfall Act—a move that would have shielded him from personal liability—had already been rejected in August 2025.
Carroll’s legal team, led by attorney Roberta Kaplan, welcomed the decision. Kaplan said, “We look forward to an end to the appellate process so that justice will finally be done.” For Carroll herself, the fight has been both public and deeply personal. Now 81, she has remained steadfast in her pursuit of accountability, even as institutions across the country have, in recent months, appeared to bend to Trump’s will. “We all get, ‘You’re ugly, you’re old, you’re shriveled. You don’t deserve this. You’re pathetic. You’re hideous. You don’t deserve to go on.’ We all are getting it. I am not unusual. Every woman in this room knows exactly what I’m talking about,” Carroll told Fortune at an event earlier this year, reflecting on the barrage of insults and threats she received after coming forward.
Carroll’s resilience has been on display not just in the courtroom, but in her continued public advocacy. She recently published a memoir, Not My Type, and a documentary about her experience has screened at film festivals, drawing further attention to her story. Despite the size of the judgment, Carroll has yet to receive any payment, as Trump’s legal team has vowed to continue fighting, potentially all the way to the Supreme Court.
The appeals court’s ruling also provided a detailed breakdown of the damages awarded. Of the $18.3 million in compensatory damages, $7.3 million was designated for reputational harm and emotional distress, while $11 million was allocated for a reputation-repair program. The punitive damages, totaling $65 million, were justified in part by Trump’s ongoing and escalating attacks on Carroll, including his public pledge to repeat his denials “a thousand times.” The court found that the punitive-to-compensatory ratio of 3.6-to-1 was within constitutional limits, given the severity and duration of Trump’s conduct.
Evidence presented at trial included the loss of Carroll’s longtime Elle magazine column, a sharp decline in professional opportunities, and the thousands of online threats and harassing messages she endured. The court noted that Carroll’s experience was emblematic of the broader challenges faced by women who speak out against powerful men, particularly in an era of social media amplification and political polarization.
Trump, for his part, has remained defiant. His legal team denounced the rulings as politically motivated and indicated plans to seek Supreme Court review. Trump himself has continued to make controversial public statements, including, on the same day as the appeals court decision, dismissing domestic violence as a “little fight with the wife” that shouldn’t count toward crime statistics—a remark that drew widespread criticism and underscored the ongoing cultural and political divisions surrounding his presidency.
The $83.3 million judgment remains in place unless the Supreme Court intervenes. In the meantime, Carroll’s case stands as a rare example of an individual successfully holding a sitting or former president accountable in a court of law. As Fortune observed, “Bending to Trump’s will is not the only way.” Institutions may feel constrained by political or financial pressures, but Carroll’s persistence has demonstrated that individuals can still make a difference—even against the most powerful figures in the country.
For now, the legal battle continues, but the impact of the appeals court’s decision reverberates far beyond the courtroom, offering both a measure of justice for Carroll and a signal that, at least in this instance, the rule of law still holds.
