Lewis A. Kaplan, US District Judge for the Southern District of New York, ruled Wednesday that former President Donald Trump was liable for sexually abusing and defaming writer E. Jean Carroll, citing a ruling from earlier this year and saying that the jury in an upcoming trial will only need to determine how much money Trump owes Carroll.
The case before the court concerned a 2019 statement from Trump denying that he sexually assaulted Carroll to a degree that Carroll claimed constituted defamation. This was similar to the case in May, where a court found that Trump was liable for sexual abuse and that comments he made in 2022 denying such allegations were defamation. Carroll was seeking summary judgment, which allows judges to rule on the merits of a case when a jury could only reasonably rule in one party’s favor.
Carroll argued that because a previous trial had already determined that Trump sexually abused her and that his 2022 comments were defamation and this trial should not re-litigate those issues under a doctrine known as “collateral estoppel.” Collateral estoppel prevents parties from re-litigating issues that are substantially the same, have already been decided through a fair proceeding, and are necessary to the outcome of the current case. Trump’s lawyers argued that his statements in 2019 and 2022 were different enough to not warrant collateral estoppel and that the court should not bind the jury to findings from the previous case.
Kaplan agreed with Carroll, finding that Trump’s 2019 and 2022 statements were substantively identical enough, thereby holding him liable for sexual abuse and defamation based on the findings of the jury in the previous trial. She did not grant a full judgment, opting instead for partial summary judgment that ruled on Trump’s liability but left the issue of monetary compensation for the upcoming jury trial.
Carroll’s lawsuit against Trump is just one of his many legal issues, as he faces criminal charges related to his attempt to overturn the 2020 election on January 6, his attempt to interfere with the 2020 election in Georgia, falsifying business records and mishandling classified documents.