Judge Lewis Kaplan issued a “partial summary judgment” that the former president had made defamatory statements with “actual malice” about Ms Carroll in 2019 after she went public with claims he had raped her decades earlier.
A civil trial scheduled for January will only determine how much the former president should pay her in monetary damages, Judge Kaplan ruled.
In May, a jury found Mr Trump liable for sexual assault and defamation of the former Elle advice columnist and awarded her $5m in damages.
In a judgment issued on Wednesday, Judge Kaplan found that the jury’s verdict in that case confirmed Mr Trump’s 2019 statements were false, and were made with “actual malice”.
“[T]he jury found that Mr Trump knew that his statement that Ms Carroll lied about him sexually assaulting her for improper and ulterior purposes was false or that he acted with reckless disregard to whether it was false. Whether Mr Trump made the 2019 statements with actual malice raises the same issue.”
He also stated that any damages awarded from the second defamation ruling should not be limited in scope by the $5m award from the previous trial.
In a statement provided to The Independent, Ms Carroll’s lawyer Robbie Kaplan said: “We look forward to trial limited to damages for the original defamatory statements Donald Trump made about our client E Jean Carroll in 2019.”
The first trial in May heard graphic testimony from the former Elle advice columnist about how she was sexually assaulted at the luxury Manhattan department store Bergdorf Goodman in the 1990s.
Ms Carroll, 79, first revealed details of the sexual assault in a book excerpt that ran in New York magazine in June 2019.
When Mr Trump angrily denied the claims and attacked her personally in White House interviews and press releases, she sued him for defamation.
The Department of Justice (DOJ) initially defended Mr Trump in the civil lawsuit, dubbed Carroll I, claiming in court documents that he was “acting within the scope of his presidential duties” when he made “crude and disrespectful” comments about Ms Carroll.
Then in March, the DOJ dropped its plans to defend the former president. It concluded that there was “no longer a sufficient basis to conclude that the former President was motivated by ‘more than an insignificant’ desire to serve the United States Government”.
In 2022, Ms Carroll sued the former president for sexual assault after New York passed a law allowing survivors a one-year window to hold their abusers accountable regardless of when the assault took place.
That case, referred to as Carroll II, went to trial earlier this year, where a nine-person jury ruled that Mr Trump was liable for sexual assault and defamation.
Lawyers for Mr Trump did not immediately respond to a request for comment.