The Second Circuit Court of Appeals rejected President Trump's effort to relitigate the jury verdict in E. Jean Carroll's defamation lawsuit, ruling that the president raised his arguments too late. The decision, reported Wednesday, leaves intact an $83 million damages award issued by a jury in 2024.
Judge Denny Chin wrote the explanation for the court's refusal to convene a full en banc rehearing of the case. His language was pointed.
"The fact of the matter is that no other defendant would be permitted to move to substitute the United States in his place, fifteen months after trial and the entry of judgment against him."
Chin added that the court "appropriately declined to convene en banc to revisit this issue." The ruling means the president's legal team failed on two fronts: an attempt to substitute the United States as the defendant and a claim of presidential immunity. Both arguments, the court found, arrived far too late in the proceedings.
Carroll, a writer, first filed suit in 2019. She alleged that Trump defamed her with statements he made while refuting her claim that he sexually assaulted her in a Bergdorf Goodman dressing room in the early 1990s. Trump has repeatedly denied those allegations. The White House on Wednesday called them "Hoaxes" and "false claims."
A separate, earlier jury found Trump liable for defamation and sexual abuse and awarded Carroll $5 million in damages. Then, in 2024, before the presidential election, a second jury handed down the far larger $83 million award. It is that second verdict Trump sought to overturn on appeal.
The Second Circuit has now weighed in more than once. A three-judge panel ruled on December 30, 2024, that Trump failed to show legal errors warranting a new trial. That panel upheld the district court's decision to admit testimony from two other women and the Access Hollywood tape as evidence, National Review reported. In an unsigned opinion, the judges wrote that Trump "has not demonstrated that the district court erred in any of the challenged rulings."
The panel also found that a jury could reasonably infer Trump "engaged in similar conduct with other women, a pattern of abrupt, nonconsensual, and physical advances on women he barely knew." That evidentiary ruling was central to the defense's appeal and central to its failure.
The appeals court pattern is not unique to this case. The Second Circuit has handed the administration setbacks on other fronts as well, contributing to a broader pattern of judicial friction with the executive branch.
Trump's legal team tried a different tack after the Supreme Court's 2024 decision on presidential immunity. They argued that ruling shielded the president from Carroll's suit entirely. The Second Circuit rejected that claim, leaving the $83.3 million jury award tied to Trump's 2019 denials firmly in place, Just The News reported.
The immunity argument was always a stretch in this context. The underlying statements at issue were Trump's public denials of Carroll's accusations, made while he was president, yes, but not in any obvious exercise of official duty. The court's reasoning tracked that distinction. Fifteen months after a trial verdict is a difficult moment to introduce a new legal theory, no matter how sweeping.
Courts across the country have been testing the boundaries of executive authority in recent months. Separate appeals courts have blocked Trump administration immigration actions, creating a patchwork of rulings that may eventually force the Supreme Court's hand on multiple fronts.
Carroll's attorney, Roberta Kaplan, celebrated the decision in a statement:
"We are pleased that the United States Court of Appeals for the Second Circuit has denied President Trump's petition for an en banc hearing in connection with the verdict from the second jury trial."
Kaplan added that Carroll "is eager for this case, originally filed in 2019, to be over so that she can finally obtain justice." The case has now wound through the courts for seven years, a timeline that underscores just how long civil litigation against a sitting or former president can drag on.
The White House pushed back hard. A spokesperson issued a statement calling for "an immediate end to the unlawful, radical weaponization of our justice system, and a swift dismissal of all of the Witch Hunts." The spokesperson characterized Carroll's allegations as hoaxes and false claims.
That framing, weaponization of the courts, has become a familiar refrain from the administration. And it is not without basis in the broader landscape. Federal judges have issued rulings that appear driven more by ideology than by law, and conservative skepticism of the judiciary's neutrality is well-earned after years of forum-shopping and nationwide injunctions.
The president may take his appeal to the Supreme Court. USA Today, as cited in the reporting, noted that Wednesday's decision could set the stage for that move. Whether the high court would take up a civil defamation case, particularly one rooted in pre-presidential conduct, is an open question. The justices have shown willingness to define presidential immunity broadly, but this fact pattern sits at the margins of that doctrine.
If the Supreme Court declines to hear the case, the $83 million verdict stands. Combined with the earlier $5 million award, Carroll would be entitled to $88 million in total damages, a staggering sum for a civil defamation and battery case.
The legal system has also been a battleground on immigration, where appeals courts have blocked executive actions and teed up their own Supreme Court confrontations. The Carroll case is different in kind, personal, not policy, but it feeds the same sense among conservatives that the courts have become another front in a political war against the administration.
Whatever one thinks of the underlying allegations, and Trump has denied them consistently, the appeals court's reasoning rested on a procedural point that is hard to argue with. Fifteen months is a long time to wait before trying to swap in the United States as a defendant. Courts enforce deadlines. They do not bend them for presidents any more than for anyone else, as Judge Chin made explicit.
The president's legal team may have stronger ground at the Supreme Court, where the immunity question can be briefed fresh. But the procedural misstep at the circuit level cost them a chance to have the full Second Circuit weigh in. That is the kind of error that matters, not because the law was unclear, but because the clock ran out.
Conservative voters have every right to question whether the legal system treats this president fairly. But the strongest answer to that question is not a late-filed motion, it is a disciplined legal strategy that forces the courts to confront the merits head-on, on time.
