Carroll v. Trump

Background

E. Jean Carroll brought a defamation case against Donald J. Trump based on three statements he made in June 2019 after Carroll publicly accused him of sexually assaulting her in the mid-1990s. Trump denied knowing Carroll, called her accusation false, and accused her of making it up for publicity, book sales, political purposes, or other improper reasons.

In an earlier related proceeding, a jury found that Trump sexually abused Carroll under the applicable New York law and defamed her in a statement he published in October 2022. The jury awarded Carroll $5 million in damages on those claims. The court explained that its ruling in this case concerned the preclusive effect of those findings and Carroll’s request for summary judgment on the liability elements of her 2019 defamation claim.

Rulings on the 2019 Statements

The court applied New York’s issue-preclusion law. Issue preclusion prevents a party from relitigating an issue when the issue is identical in both proceedings, was actually litigated and decided, was subject to a full and fair opportunity to litigate, and was necessary to support a valid final judgment.

The court held that the earlier jury’s findings established that Trump’s 2019 statements were defamatory, false, and made with actual malice. The court reasoned that the 2019 and 2022 statements had substantially the same core content: they accused Carroll of lying about the sexual assault and suggested that she had improper reasons for making the accusation. The earlier jury’s finding that the 2022 statement was false necessarily established, for purposes of this case, that Carroll had not fabricated her sexual-assault accusation.

The court also held that the earlier finding of actual malice applied to the 2019 statements. “Actual malice” means that the speaker knew a statement was false or acted with reckless disregard for whether it was true. The court alternatively concluded that the undisputed evidence independently established actual malice, including evidence that Trump did not investigate Carroll’s account before making the statements.

The court separately concluded that Carroll was entitled to summary judgment on the issues of whether the 2019 statements were published to a third party and concerned Carroll, because Trump did not dispute those elements. The court also found that no reasonable jury could conclude that the statements lacked defamatory meaning, given the accusations that Carroll fabricated a sexual-assault allegation for improper purposes.

The court did not decide whether summary judgment should be granted or denied concerning the portion of Trump’s June 24, 2019 statement stating, “it never happened.”

Damages and Disposition

Trump argued that any damages in this case should be capped by damages awarded in the earlier related proceeding, including a $1 million award for harm other than a reputation-repair program and a $1.7 million award connected to that program. The court rejected both arguments. It held that the earlier jury had not decided how much harm the 2019 statements caused, and that Trump had not shown that the earlier award required a reduction of any future award for a reputation-repair program in this case.

The court granted Carroll’s motion for partial summary judgment except as to Trump’s June 24, 2019 statement. It denied Trump’s motion concerning the preclusive effect of the earlier jury verdict. The court stated that the trial in this case would be limited to damages. Trump’s separate request concerning a counterclaim was denied as moot because the court had already dismissed that counterclaim. The court also declined Carroll’s request to consider an order requiring Trump’s attorneys to explain why they should not pay her attorneys’ fees.