A federal judge on Wednesday sided with writer E. Jean Carroll, ruling that former President Donald Trump defamed her in 2019 and limiting his upcoming trial to determining how much he will pay in damages.
U.S. District Judge Lewis Kaplan found that a trio of statements made by Trump in 2019, after Carroll’s allegations against him first surfaced, were “substantially the same” as one from 2022 that a jury deemed defamatory in May.
The jury’s May verdict “plainly established that Mr. Trump’s 2019 statements were false,” Kaplan wrote in a memorandum opinion published Wednesday.
“In (the earlier case), the truth or falsity of Mr. Trump’s 2022 statement — which … accused Ms. Carroll of lying about Mr. Trump sexually assaulting her for improper and ulterior purposes — depended upon whether Mr. Trump sexually assaulted Ms. Carroll,” he wrote. “The jury answered that question in the affirmative twice. First, it found by a preponderance of the evidence that Mr. Trump sexually abused Ms. Carroll. Second, it determined by clear and convincing evidence that Mr. Trump’s 2022 statement was false.”
The judge determined that while the jury was ordered not to consider the 2019 statements, “that point does not change the fact that the jury considered and decided issues that are common to both cases — including whether Mr. Trump falsely accused Ms. Carroll of fabricating her sexual assault charge and, if that were so, that he did it with knowledge that his accusation was false and (that) he knew it was false or acted with reckless disregard as to its truth.”
Trump argued that the jury was not asked to consider whether his 2022 statement was made for a “nefarious purpose” or whether he lied when he claimed he did not know Carroll, allegations that Kaplan said “(defy) common sense” and mischaracterize her defamation claim.
“Of course, the jury’s finding that the sexual assault occurred necessarily implies that Ms. Carroll did not lie about it for a nefarious or any other purpose and that Mr. Trump met and knew her,” the judge wrote.
“In any event, Ms. Carroll did not sue Mr. Trump simply for stating that he did not know her. His statement that he did not know her is a subcomponent of the core of Ms. Carroll’s defamation claim, which … is that Mr. Trump defamed her in this case and in (the previously decided case) by accusing her of concocting a sexual assault allegation for improper purposes.”
Trump also argued that damages for the 2019 statements should be limited by those awarded by the jury in May, an argument the judge rejected as a misinterpretation of the jury’s findings.
Jurors found Trump liable for sexually assaulting Carroll in a dressing room at a luxury department store in New York City in the 1990s and defaming her in a 2022 social media post in which he claimed she was lying and that he did not know her. The jury ordered him to pay Carroll $5 million as part of the case.
A jury is set to determine damages for the 2019 statements in a trial set to begin in January 2024.
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