E. Jean Carroll v. Trump: Verdicts, Appeals, and DOJ Probe

E. Jean Carroll v. Donald Trump refers to two federal lawsuits the writer brought against the former president: a 2022 case for battery and defamation that produced a $5 million jury verdict in May 2023, and an earlier 2019 defamation case that produced an $83.3 million verdict in January 2024. Trump is appealing both. As of mid-2026, he has paid neither, having posted a bond of roughly $100 million to stay enforcement while the Supreme Court considers whether to take up the smaller verdict and while a petition on the larger one is expected.

How the Two Lawsuits Fit Together

Carroll went public in June 2019 with an accusation that Trump had sexually assaulted her in a Bergdorf Goodman dressing room in the mid-1990s, in an excerpt from her memoir published in New York magazine. Trump denied ever meeting her and said she was “not his type.”¹

The statute of limitations on the assault itself had long expired, so Carroll’s first suit, filed in 2019 and known as Carroll I, targeted only Trump’s denials as defamatory. It was removed to federal court in September 2020 and assigned to U.S. District Judge Lewis Kaplan in the Southern District of New York.²

New York’s Adult Survivors Act, passed in May 2022, briefly reopened the window on time-barred sexual assault claims. Carroll used it to file a second suit, Carroll II, alleging battery for the assault itself along with a fresh defamation claim tied to a 2022 social media post in which Trump called her accusations a “complete con job” and a “Hoax.”³ Judge Kaplan tried Carroll II first and stayed Carroll I.

The $5 Million Verdict for Sexual Abuse and Defamation

Carroll II went to trial in April and May 2023. In pretrial rulings, Judge Kaplan admitted “propensity evidence” under Federal Rule of Evidence 415, including the “Access Hollywood” tape and testimony from two other women who accused Trump of sexual assault.⁴ In a videotaped deposition, Trump mistook a photograph of Carroll for his ex-wife, undercutting his “not his type” defense. He did not testify at trial and called no witnesses.

On May 9, 2023, after about three hours of deliberation, the jury unanimously found Trump liable for sexual abuse and defamation and awarded Carroll $5 million: $2 million in compensatory damages for battery, $2.7 million in compensatory damages for defamation, and $280,000 in punitive damages.⁵ The jury did not find Trump liable for “rape” under New York’s narrow penal definition, which requires penile penetration; Judge Kaplan later clarified that the jury’s sexual abuse finding covered what most people would understand as rape in common usage. Judge Kaplan denied Trump’s motion for a new trial on July 19, 2023.⁶

The $83.3 Million Defamation Verdict

With Carroll II decided, the original defamation case moved to trial in January 2024. Judge Kaplan had already ruled as a matter of law that Trump’s 2019 statements were defamatory, so the jury’s job was to set damages. Trump attended intermittently, made audible comments calling the case a “witch hunt” and a “con job,” and walked out during closing arguments; Judge Kaplan warned that his right to be present “can be forfeited.”⁷

On January 26, 2024, the jury awarded Carroll $83.3 million: $18.3 million in compensatory damages and $65 million in punitive damages.⁸ Denying Trump’s post-trial motion in April 2024, Judge Kaplan cited the “reprehensibility” of Trump’s conduct and noted that Trump had continued defaming Carroll during the trial itself, making a “significant deterrent” necessary.⁹

Where the Appeals Stand

Trump appealed both judgments. His core arguments have leaned on presidential immunity and the Westfall Act, under which he tried to substitute the United States as the defendant on the theory that his statements were made in his official capacity.

On the $5 million verdict, the Second Circuit unanimously affirmed on December 30, 2024, and the full court denied rehearing in June 2025.¹⁰ Trump petitioned the Supreme Court (Docket No. 25-573), arguing the lower courts should not have admitted testimony from other accusers or the “Access Hollywood” tape.¹¹ As of June 2026, the Court had rescheduled the case for conference at least eleven times without acting on it.¹²

On the $83.3 million verdict, a Second Circuit panel upheld the judgment and in April 2026 the full court denied Trump’s petition for rehearing, with the majority holding that presidential immunity is a waivable defense and that Trump had waived it.⁸ Three dissenting judges argued the majority had created a circuit split on the Westfall Act. Trump has indicated he plans to seek Supreme Court review of this verdict as well, though as of mid-2026 no petition had been filed.¹²

Trump has not paid either award. In March 2024, he posted a $91.6 million supersedeas bond through the Federal Insurance Company to cover the $83.3 million judgment plus interest.¹³ In May 2026, the Second Circuit stayed enforcement pending Supreme Court review and ordered Trump to raise his bond by $7.4 million to cover accrued interest, bringing the total to nearly $100 million, according to Carroll’s attorney.¹⁴

The Funding Controversy and DOJ Investigation

At an October 2022 deposition, Trump’s attorney Alina Habba asked Carroll whether anyone else was paying her legal fees. Carroll answered “No.”¹⁵ In April 2023, her lawyers told Trump’s team that her memory had been “refreshed” and that her counsel had secured outside funding from a nonprofit in 2020.¹⁶

The nonprofit was American Future Republic, a 501(c)(4) social welfare organization founded in 2019 with LinkedIn co-founder Reid Hoffman as its president.¹⁷ Its 2020 tax records showed a $7 million payment to Kaplan Hecker & Fink, Carroll’s law firm.¹⁸ Dmitri Mehlhorn, an adviser to Hoffman, said the initial grant predated Carroll’s suit, was intended for broader public interest litigation, and that clients “generally do not know our identity.”¹⁹

The Second Circuit rejected Trump’s arguments that the undisclosed funding undermined Carroll’s credibility, finding “no evidence to suggest that Ms. Carroll was personally involved in securing the funding, interacted with the funder,” or knew about it before her deposition, and concluding she “simply was not involved in the matter of who was or was not funding her litigation costs.”¹⁸

In May 2026, news outlets reported that the Justice Department had opened a criminal investigation focused on American Future Republic and its funding of Carroll’s legal expenses, examining potential money laundering, obstruction, and conspiracy.²⁰ Prosecutors are also looking at whether Carroll committed perjury in her deposition testimony about the funding, though sources told multiple outlets that Carroll is not a subject of the investigation and that the primary focus is the nonprofit.²¹

The investigation is being managed out of the deputy attorney general’s office. Acting Attorney General Todd Blanche recused himself because he previously served as one of Trump’s personal attorneys on Carroll-related appeals.²² Senior DOJ leaders referred the matter to federal prosecutors in Chicago, where American Future Republic is based.²³

On May 28, 2026, U.S. Attorney Andrew Boutros, the top federal prosecutor in Chicago, issued a statement saying his office “has not opened — and has never opened — a criminal investigation into E. Jean Carroll” and called reports to the contrary “categorically false.”²⁴ Sources reaffirmed the investigation to multiple outlets, and a prosecutor in Boutros’s office, William Hogan, was identified as leading it.²⁵ Hoffman called the allegations “absurdly false.”¹⁶ Carroll’s legal team declined to comment.

News organizations have placed the probe in a broader pattern of Justice Department investigations into people Trump has publicly identified as adversaries. Other targets have included former FBI Director James Comey, New York Attorney General Letitia James, and the Southern Poverty Law Center; charges against Comey and James were dismissed after a judge ruled the presiding prosecutor was unlawfully appointed.²⁶

Carroll’s Attorney

Roberta Kaplan has represented Carroll since 2019 and is the only attorney to have deposed Trump twice. Her strategy relied heavily on Trump’s own public statements and deposition testimony, and both juries reached their unanimous verdicts in under three hours.²⁷ She originally handled the cases through Kaplan Hecker & Fink and, after leaving that firm in June 2024, has continued to represent Carroll through the appeals at her new firm, Kaplan Martin.²⁸

1
First Amendment Watch. Timeline: E. Jean Carroll v. Donald Trump and the Defamation Legal Battle
2
CourtListener. Carroll v. Trump, Case No. 1:20-cv-07311
3
SCOTUSblog. Justices to Consider Whether to Weigh in on $5 Million Verdict Against Trump at Next Conference
4
NITA. Carroll v. Trump: A Case Won in Pretrial
5
NPR. Trump Carroll Verdict
6
Findlaw. Carroll v. Trump, S.D.N.Y.
7
BBC. E. Jean Carroll Defamation Trial
8
Courthouse News Service. No En Banc in Trump Appeals of E. Jean Carroll Verdict, $83 Million Judgment
9
Courthouse News Service. Federal Judge Denies Trump Motion for New Trial in E. Jean Carroll Defamation Suit
10
Justia. Carroll v. Trump, No. 23-793
11
SCOTUSblog. Trump v. Carroll
12
SCOTUSblog. Court Puts Off Deciding Whether to Consider $5 Million Verdict Against Trump Yet Again
13
ABC News. Trump Secures $91 Million Bond Judgment Jean Carroll
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PBS. Appeals Court Says Trump Doesn’t Have to Pay $83 Million to E. Jean Carroll for Now
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Washington Examiner. DOJ Criminal Investigation E. Jean Carroll
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NBC News. DOJ Opens Criminal Probe Trump Accuser E. Jean Carroll
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ProPublica. American Future Republic
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CBS News. Justice Dept Reid Hoffman E. Jean Carroll Trump Lawsuits
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CNN. Reid Hoffman E. Jean Carroll Probe Nonprofit Trump Critics
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The Guardian. E. Jean Carroll DOJ Trump Reid Hoffman
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Axios. DOJ E. Jean Carroll Funding Reid Hoffman Review
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CNN. Justice Department Launched E. Jean Carroll Investigation
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Washington Post. DOJ Probes Reid Hoffman’s Nonprofit Funding E. Jean Carroll’s Legal Bills
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NBC Chicago. Embattled Illinois U.S. Attorney Now Investigating Trump Accuser E. Jean Carroll
25
CNN. Chicago U.S. Attorney E. Jean Carroll Turmoil
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NPR. Justice Department Opens Investigation Into Trump’s Accuser E. Jean Carroll
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Kaplan Martin. Roberta Kaplan
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New York Times. Roberta Robbie Kaplan