This appeal arises from a civil trial in the Southern District of New York where a jury found that Donald Trump sexually abused E. Jean Carroll in a Bergdorf Goodman dressing room in 1996 and defamed her in statements made in 2019 and 2022. The jury awarded Carroll a total of $5 million in damages. Trump appealed, arguing that the district court committed reversible error by admitting evidence of other sexual assaults under Federal Rule of Evidence 415 and by excluding evidence he sought to use to challenge Carroll's credibility. The district court had permitted the admission of testimony from two other women alleging past misconduct by Trump and a recording of a 2005 conversation where Trump described grabbing women without consent. Conversely, the district court excluded evidence regarding the source of Carroll's legal funding, a transcript of an interview between Carroll and one of the other witnesses, and certain cross-examination questions about DNA evidence and the failure to file a police report.
The Second Circuit reviewed the district court's evidentiary rulings for abuse of discretion. First, the court addressed the admissibility of other sexual assault evidence under Rule 415. The court held that the trial was a civil case involving a claim based on sexual assault, making Rule 415 applicable. It affirmed the admission of testimony from Jessica Leeds and Natasha Stoynoff, finding that a jury could reasonably conclude by a preponderance of the evidence that Trump committed other sexual assaults. The court specifically addressed the jurisdictional argument regarding Rule 413(d)(1), ruling that the rule applies to conduct prohibited by federal chapter 109A based on the nature of the act, not the specific location where it occurred. The court also upheld the admission of the Access Hollywood tape under both Rule 415 and Rule 404(b), finding it probative of a pattern of conduct and relevant to corroborate witness testimony. Second, the court reviewed the exclusion of evidence. It found no abuse of discretion in excluding litigation funding evidence, as it had minimal probative value regarding credibility and was outweighed by the risk of unfair prejudice. The court also upheld the exclusion of the Stoynoff transcript, noting that while the statements were admissible as party admissions, the district court acted within its discretion to exclude the document to avoid confusion and delay, especially since the information was available through cross-examination. Finally, the court affirmed the exclusion of cross-examination regarding DNA evidence and the failure to file a police report, citing the potential for confusion, delay, and the lack of a factual basis for the questions.
The $5 million judgment against Donald Trump stands, and the jury's findings of sexual abuse and defamation remain in full force. The decision reinforces the Second Circuit's application of Federal Rules of Evidence 413, 414, and 415, clarifying that the jurisdictional elements of federal criminal statutes do not limit the admissibility of prior bad acts evidence in civil cases when the conduct itself falls within the prohibited categories. The ruling also signals that district courts have broad discretion to exclude evidence that risks confusing the issues or causing undue delay, even if the evidence might be marginally relevant to credibility.
Podcast (federal-narrative-summaries): Play in new window | Download