What did the Second Circuit say in its written opinion affirming the $5 million judgment in Carroll v. Trump?
Executive summary
The Second Circuit’s written opinion affirmed the district court’s $5 million judgment for E. Jean Carroll, holding that the trial court’s evidentiary rulings fell “within the range of permissible decisions” and that any asserted errors were harmless; the appeals court therefore upheld the compensatory and punitive award returned by the jury [1] [2] [3].
1. What the panel said — affirmation and harmless-error review
The court’s per curiam ruling affirmed the district court’s judgment and explained that on appeal it must construe the record in favor of the jury winner, here Carroll, and that Trump had not shown any alleged evidentiary error affected his substantial rights; accordingly the panel found no reversible abuse of discretion and affirmed the $5 million verdict [2] [3] [1].
2. Evidentiary rulings at the center of the dispute
A central part of the opinion analyzes multiple evidentiary decisions by the trial judge — including admission or exclusion of certain background and propensity evidence — and concludes those rulings were within the permissible range of discretion; where error might be claimed the panel found it harmless in light of the overall record [1] [3] [2].
3. Propensity evidence and Rules 413–415
The written opinion addressed the admissibility of three categories of evidence under Federal Rules of Evidence 413–415, concluding that those materials were properly received as evidence that a party committed “any other sexual assault,” and stressing that those rules reflect Congress’s considered judgment to allow propensity evidence in certain sexual-assault civil cases [4].
4. Standard of review and the appellate posture
The panel repeatedly emphasized the narrowness of appellate review from a jury verdict: appellate courts must draw all inferences and make credibility determinations in favor of the prevailing party, and the Second Circuit applied that constraint when rejecting Trump's challenge that the evidentiary decisions prejudiced his defense [2].
5. Damage award and what was upheld
The court affirmed the jury’s combined compensatory and punitive damages totaling $5 million for sexual abuse and related defamatory statements, leaving intact the monetary judgment that had been entered following the May 2023 trial [2] [5] [6].
6. Dissent and later procedural moves
Although the panel affirmed in December 2024, subsequent procedural history shows the court later declined rehearing en banc, with a reported 8–2 vote and noted dissents from Judges Menashi and Park expressing disagreement with the panel’s approach; those developments demonstrate there were at least some appellate judges willing to question the panel’s treatment of certain issues [7] [6].
7. What the opinion did not decide or address
The panel’s per curiam opinion did not revisit every doctrinal battleground from related Carroll appeals — for example, broader questions about presidential immunity and separate higher-value defamation awards were litigated in companion appeals and motions, and some of those issues were the subject of distinct opinions and subsequent petitions; the written opinion affirming the $5 million judgment focused on the evidentiary challenges and harmless-error analysis specific to that verdict [8] [6] [9].
Bottom line
The Second Circuit’s written opinion sustained the jury’s factual findings and $5 million judgment by concluding the trial judge’s evidentiary decisions were well within permissible bounds and that any perceived mistakes did not change the outcome, while later procedural developments — including a denied rehearing en banc with noted dissents — signal ongoing appellate contention over related legal questions [1] [3] [7].