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Jul 15, 2026

TRUMP'S COURTROOM WALKOUT RETURNS TO SPOTLIGHT AS $83.3M CARROLL JUDGMENT REACHES SUPREME COURT

NEW YORK — Updated September 10, 2026

One of the most dramatic moments in Donald Trump's civil litigation with writer E. Jean Carroll came on January 26, 2024, when Trump abruptly left a Manhattan federal courtroom during Carroll attorney Roberta Kaplan's closing argument. Minutes earlier, U.S. District Judge Lewis A. Kaplan had sharply rebuked Trump lawyer Alina Habba, telling her she was 'on the verge of spending some time in the lockup' after she persisted in challenging a ruling about material the defense wanted to display to jurors.

The confrontation was real, but several viral retellings overstate what happened. The judge did not jail Habba, hold her in contempt, or impose a criminal sanction. And while news reports often described Trump as having 'stormed out,' the official appellate record uses the more neutral description that he stood up and walked out during Carroll's closing argument. He later returned for the defense summation.

FACT-CHECK AT A GLANCE
• VERIFIED: Judge Kaplan told Alina Habba she was 'on the verge of spending some time in the lockup' after she continued disputing a ruling before the jury entered.
• VERIFIED: Trump stood up and walked out during Roberta Kaplan's closing argument on January 26, 2024, and later returned for his own side's closing.
• CONTEXT: 'Stormed out' is a journalistic characterization; the court record itself says he stood up and walked out.
• VERIFIED: The jury awarded $18.3 million in compensatory damages and $65 million in punitive damages, totaling $83.3 million.
• IMPORTANT: The 2024 proceeding concerned damages for Trump's 2019 defamatory statements. Liability had already been resolved by the court through issue preclusion based on the earlier Carroll verdict.
• CURRENT STATUS: The Second Circuit affirmed the $83.3 million judgment in September 2025 and denied rehearing en banc in April 2026. Trump filed a Supreme Court petition in July 2026; as of September 10, 2026, the Court has not ruled on that petition.

The Morning Began With a Fight Over What the Jury Could See

Court reporting from the final day describes Trump's team as arriving late, with tension already high before jurors entered. The immediate dispute concerned a presentation slide the defense wanted to use during closing arguments. Carroll's lawyers objected that the material had not been admitted into evidence, and Judge Kaplan ruled that it could not be shown to the jury.

Habba continued trying to argue the point. Kaplan cut her off with the now widely quoted warning that she was 'on the verge of spending some time in the lockup' and ordered her to sit down. The exchange was an unusually sharp courtroom rebuke, but it should not be rewritten as though the judge actually ordered Habba jailed. No such confinement occurred.

UPDATE: Trump denies Carroll's sexual abuse claims as defamation trial  nears end | 1470 & 100.3 WMBD

Trump Left During Carroll's Closing Argument

When the jury returned, Roberta Kaplan began arguing that the damages award needed to be large enough to compensate Carroll and deter further defamation. She emphasized that Trump had continued attacking Carroll after the earlier May 2023 verdict and during the litigation.

Roughly minutes into that closing argument, Trump rose from the defense table and left. Judge Kaplan interrupted briefly so the event would be captured in the record, noting that Trump had risen and walked out. Trump remained absent for the rest of Carroll's closing but came back before Habba delivered the defense summation.

COURTROOM RECORD
The record will reflect that Mr. Trump just rose and walked out of the courtroom.

The timing made the moment politically and visually striking, because Carroll's lawyers were arguing that ordinary rules and prior verdicts had not deterred Trump. But a careful account should stop short of claiming that the walkout itself caused the eventual award. Jurors do not issue explanations of how much weight they assign to individual courtroom moments, and the verdict form did not say that the exit added a particular dollar amount.

What the Jury Was Actually Deciding

The January 2024 proceeding was not a fresh trial on whether the underlying assault allegation was true. In a separate case tried in May 2023, a jury found Trump liable for sexually abusing Carroll under New York civil law and for defaming her in a 2022 statement. That jury awarded $5 million.

After that verdict, Judge Kaplan applied issue preclusion in the older defamation case involving statements Trump made in June 2019 while he was president. As a result, the 2024 jury was tasked principally with determining damages for those 2019 statements rather than relitigating liability from scratch.

That distinction matters. Viral summaries sometimes merge the two Carroll cases into a single proceeding. They were related, but legally distinct: one produced the $5 million verdict in 2023; the other produced the $83.3 million damages award in 2024.

Trump Ordered to Pay E. Jean Carroll $83 Million in Damages

The $83.3 Million Verdict

The nine-person jury awarded Carroll $11 million for a reputation-repair program and $7.3 million in other compensatory damages, for a total of $18.3 million in compensatory damages. It then awarded another $65 million in punitive damages after finding common-law malice under the court's instructions.

Punitive damages are designed to punish sufficiently blameworthy conduct and deter similar conduct in the future. The Second Circuit later noted that jurors were specifically instructed to consider the amount necessary to deter Trump from continuing to defame Carroll. That is more precise than saying punitive damages are simply 'a verdict about character,' which is rhetoric rather than a legal definition.

The Appeals Did Not End in 2025

Trump appealed the $83.3 million judgment. On September 8, 2025, a three-judge panel of the U.S. Court of Appeals for the Second Circuit affirmed the district court's judgment in full, rejecting his arguments concerning presidential immunity, issue preclusion, evidentiary rulings, jury instructions, and the size of the damages award.

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