How did courts treat presidential immunity claims in E. Jean Carroll's defamation suits against Donald Trump?

1. Waiver: the initial legal roadblock that doomed the immunity defense

The Second Circuit’s foundational ruling was procedural: judges concluded Trump had waived an absolute presidential-immunity defense because he failed to assert it as an affirmative defense in his answer to Carroll’s complaint, and therefore the defense was forfeited—an outcome the appeals court affirmed when it rejected his effort to dismiss the defamation suit on immunity grounds ^{[1] [2]}.

2. The substance of the immunity claim and why courts treated it narrowly

Courts treated Trump’s claim of absolute presidential immunity skeptically in part because the disputed statements—public denials and attacks on Carroll after she accused him of sexual assault—were characterized by Carroll as quintessentially personal and defamatory rather than part of official presidential duties, an important framing the district court and appellate panels relied on in rejecting immunity as a defense to civil liability ^{[4] [5]}.

3. Appeals, Supreme Court developments, and the reshaped argument

After the Second Circuit rejected the immunity defense, Trump’s lawyers argued that a later, broader Supreme Court decision (described in reporting as expanding presidential immunity in 2024) should alter the legal landscape and invalidate or reduce Carroll’s verdicts; the president’s legal team sought Supreme Court review and pressed that newly articulated immunity doctrine as grounds to overturn jury awards ^{[6] [2]}.

4. Courts’ response to the Supreme Court’s immunity ruling: appellate reaffirmation

Appellate panels confronted the argument that the Supreme Court’s 2024 ruling created new immunity protections and concluded it did not change the outcome in Carroll’s cases: the Second Circuit and later three-judge panels repeatedly found no reason to revisit their earlier waiver conclusion and held that Trump “failed to identify any grounds” warranting reconsideration of presidential immunity in this civil defamation context, which led to upholding multi-million-dollar verdicts against him ^{[3] [7] [8]}.

5. The stakes: damages, timing, and divergent legal narratives

Judges emphasized that the liability and damages—culminating in an $83.3 million award in one case—were informed by findings that Trump’s attacks on Carroll persisted for years and caused substantial harm, and appellate courts found the jury awards reasonable in light of those facts while rejecting claims the damages were excessive or that immunity should erase them ^{[9] [7]}. Trump’s lawyers countered that immunity is not waivable and that the Supreme Court’s broader conception of presidential immunity should apply, calling the appellate rulings “fundamentally flawed” and signaling continued litigation up to the high court ^{[8] [2] [10]}.

6. What the rulings mean — and what they don’t resolve

The courts’ treatment establishes two durable points within the recorded litigation: procedural waiver can bar an immunity defense if not timely raised, and appellate panels have declined to extend presidential-immunity precedents to shield off-duty, allegedly defamatory speech in Carroll’s cases; those holdings were reiterated even after a subsequent Supreme Court decision expanding criminal immunity, but the broader constitutional questions about the scope of immunity in civil suits—especially post-Supreme Court doctrinal shifts—remained contested and were the subject of further appeals and calls for Supreme Court review ^{[1] [6] [3]}. Reporting does not supply a final Supreme Court resolution of the immunity issue in Carroll’s specific defamation suits, so courts’ rulings described here reflect the state of adjudication in the cited coverage ^{[2] [3]}.