As E. Jean Carroll’s Book Sales Soar, Trump Is Relentlessly Trying To Claw Back the $88 Million Court Says He Owes Her

The longtime advice columnist has parlayed her victories in court into brisk book sales.

Michael M. Santiago/Getty Images
E. Jean Carroll leaves Manhattan Federal Court following the conclusion of her civil defamation trial against President Trump. Michael M. Santiago/Getty Images

The romance and sex columnist E. Jean Carroll has been a writer for years, but never has she enjoyed the sales success that her latest book, “Not My Type: One Woman vs. a President,” has accrued in the two weeks since its publication. 

“Not My Type,” which now sits in second place on the New York Times’s best-seller list for nonfiction, promises to put readers “in a better seat than the jury box.” It was juries across two civil trials — both presided over by Judge Lewis Kaplan — that awarded Ms. Carroll, 81, some $88 million in damages against President Trump for sexual abuse and defamation. Mr. Trump, trying to claw back his obligation to pay that stratospheric sum, has appealed those verdicts to the Second United States Appeals Circuit.

Mr. Trump has in the meantime secured a bond of $96.1 million, which is more than the value of the judgment because it accounts for interest. By securing the bond, Mr. Trump prevents Ms. Carroll from immediately collecting the judgments. The bond is supplied by Federal Insurance Co., a division of the insurer Chubb. It is not disclosed what properties Mr. Trump pledged as collateral to obtain the bond. 

Ms. Carroll alleged, in a book titled “What Do We Need Men For? A Modest Proposal,” that Mr. Trump assaulted her in a Bergdorf-Goodman fitting room in 1995 or 1996. Mr. Trump denied that claim in 2019, prompting Ms. Carroll to sue him for defamation. She won that jury trial to the tune of an $83 million settlement. Ms. Carroll sued Mr. Trump again in 2023, again for defamation, and this time for battery. A second trial ensued, which netted Ms. Carrol; another $5 million or so. Mr. Trump has appealed — so far unsuccessfully — for review of that verdict.

Ms. Carroll testified that Mr. Trump raped her. The jury found that claim was not supported by a preponderance of the evidence, but did find evidence of abuse. Judge Kaplan prevented Mr. Trump from contesting a finding that a contention that he raped Ms. Carroll was “substantially true under common modern parlance.” ABC News, though, settled its own defamation case against Mr. Trump for $15 million after anchor George Stephanopoulos claimed on-air that Mr. Trump was found “liable for rape.”   

Last week Mr. Trump argued on appeal that the $83 million verdict “severely damages the presidency” because “President Trump was denied the protection of presidential immunity.” Judge Kaplan found that Mr. Trump’s declaration that Ms. Carroll’s claims “should be sold in the fiction section” was inherently defamatory, and turned to the jury to determine damages.

President Donald Trump speaks to reporters in the Oval Office of the White House, Friday, May 23, 2025, in Washington. (AP Photo/Evan Vucci, File)
President Trump speaks to reporters in the Oval Office of the White House, May 23, 2025. AP/Evan Vucci

Trump v. United States, which was decided in July of last year, held that official presidential acts are presumptively immune from prosecution, while unofficial ones are bereft of such protection. Mr. Trump argues on appeal that his defamatory statements ought to be reckoned as official acts because they came in response to “reporter inquiries about a matter of public interest.”

Ms. Carroll’s attorney, Roberta Kaplan, argued that “presidential immunity can be waived, and that Trump waived it here. That’s the law of the case.” Ms. Kaplan contends that because immunity was not raised earlier, it cannot be claimed on appeal. The three-judge panel that heard oral arguments included Judges Sarah A.L. Merriam and Maria Araújo Kahn, appointed by President Biden, and Judge Denny Chin, an appointee of President Obama.

That same panel earlier this month rejected the Department of Justice’s request to substitute itself for Mr. Trump as a defendant in the case. That would have meant that the case’s legal bills would have been covered by the government rather than Mr. Trump. The DOJ had argued that substitution is required because “the United States is the party defendant unless and until a court rules to the contrary.”  

Ms. Carroll, who was Playboy’s first female editor at large, for 27 years wrote an “Ask E. Jean” advice column for Elle magazine. The title of her latest book is taken from Mr. Trump’s explanation, when confronted by her accusation, that “she’s not my type.” If Mr. Trump fails again before the Second Circuit, the final chapter in this case could be written, via appeal, at the Supreme Court. 

A state appellate court is also set to hear his request for review in respect of his 34 criminal convictions for falsification of business records related to payments to an adult film star, Stormy Daniels. Judge Juan Merchan in that case sentenced Mr. Trump to an unconditional discharge, meaning there is no prison, probation, or any other penalty other than Mr. Trump becoming a convicted felon. 

Briefing in that case, where Mr. Trump has already filed notice of his appeal, could be coming soon. If the 47th president’s arguments do not hit the docket by July 7, they will be rolled over to the New York review tribunal’s next term. Mr. Trump’s challenge to Judge Merchan’s verdict is likely to center on presidential immunity and the judge’s jury instruction, which allowed jurors to reach a “guilty” verdict even if they differed on Mr. Trump’s ultimate intent.


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