A federal judge has delivered the writer E. Jean Carroll another victory in her ongoing legal battle against former President Donald Trump.

Judge Lewis Kaplan ruled that inherent to a jury's verdict in May finding Trump liable for sexual abuse and defamation was the conclusion that another statement made by Trump in 2019 was made with "actual malice."

That statement, one of many in which Trump denied sexually abusing Carroll during a 1990s encounter in a New York City department store, is the focus of a second trial scheduled for January 2024.

Kaplan ruled Wednesday that there's no longer a question as to whether Trump defamed Carroll in 2019, and that the trial scheduled for January will merely determine what further damages Carroll is owed. Trump denies defaming Carroll, and opposed her motion seeking to limit the January trial to damages.

In May, a jury concluded Carroll was owed $5 million from Trump for both the 1990s sexual abuse and a 2022 defamatory statement made by Trump denying the abuse and calling Carroll's claim a "con job" and "hoax."

Alina Habba, an attorney for Trump, said she is "very confident" that the jury's verdict in May will be overturned on appeal and "render this decision moot." 

"We also anticipate that the Second Circuit will stay this trial as it considers the meritorious defenses that have been raised by President Trump," Habba said.

Roberta Kaplan, an attorney for Carroll who is unrelated to Judge 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."

Wednesday's decision comes as Trump faces a gantlet of legal challenges. He's currently scheduled for a trio of criminal trials in March and May 2024. In those cases, he has entered not guilty pleas to federal charges related to an alleged scheme to interfere with the peaceful transfer of power after he lost the 2020 presidential election and allegations that he unlawfully retained classified material after leaving the White House, as well as New York State charges that he falsified business records related to an alleged "hush money" payment before his 2016 election.

A trial date has not yet been scheduled in a fourth criminal case, in which Trump entered a not guilty plea to state charges in Georgia related to a "criminal enterprise" allegedly formed around an effort to thwart certification of the state's 2020 election results.

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• Donald Trump

Graham Kates

Graham Kates is an investigative reporter covering criminal justice, privacy issues and information security for CBS News Digital. Contact Graham at [email protected] or [email protected]