Part II · Proximity and Awareness

Found Liable

Part 2 of Proximity and Awareness — the cases against Donald Trump that the courts have already adjudicated

Dr. Yamicia Connor, MD, PhD, MPH · June 2, 2026

In May 2023, a federal jury found Donald Trump liable for sexual abuse. In January 2024, a second federal jury found him liable for defamation of his victim and awarded her $83.3 million. He is, as a matter of judicial fact, the first American president — sitting or former — to have been found by a court to have committed a sexual assault. This piece is the record of how the courts arrived there, and the broader record of conduct that the Carroll trials made admissible.

Part One was about proximity. This one is about adjudication.

The Carroll verdicts changed the register of what we are allowed to say about Donald Trump. Before May 9, 2023, the careful clinical sentence was: "Donald Trump has been accused by twenty-six women of sexual misconduct." After May 9, 2023, the careful clinical sentence is: "Donald Trump has been found liable in federal court for the sexual abuse of E. Jean Carroll, and has been accused by twenty-six others." A jury did that work. Nine people — six men, three women — sat in a federal courtroom in Manhattan for two weeks, listened to the evidence, deliberated for under three hours, and returned a verdict that legally established the President of the United States as a man who, by a preponderance of the evidence, sexually assaulted a woman in a department store dressing room.

I have wanted to write about the Carroll verdicts for almost three years and have not been able to. The reason is the same reason I had trouble writing Part One. The political polarization around Trump is total. The careful clinical sentence about the jury finding gets routed, on both sides, into the political question of whether he should be president — which is not the question I am asking. The question I am asking is the question I have been asking in every chapter of this book. What does the documented record show, and what does it mean that the documented record was insufficient to move the electorate.

This piece is the documented record. The Carroll II verdict on sexual abuse. The Carroll I verdict on defamation. The Federal Rules of Evidence that allowed pattern witnesses to testify. The 28 named accusers across four decades. The Access Hollywood tape that the prosecution used as a verbal blueprint. The Miss USA and Miss Teen USA dressing-room accounts and the Howard Stern recording in which Trump described the practice in his own words. The 1989 Ivana deposition. The 1993 Stacey Williams account that closes the loop back to Part One.

I am going to put it down here without commentary in the body. The body is the chart. The clinical reading of the chart belongs at the close.

Carroll II — May 2023

On May 9, 2023, a jury of nine — six men, three women — in the United States District Court for the Southern District of New York returned a verdict in Carroll v. Trump. The case had been brought under the New York Adult Survivors Act, a 2022 statute that opened a one-year window for survivors of adult sexual assault to file civil claims that had been time-barred under prior statutes of limitations.

The jury found, by a preponderance of the evidence, that Donald Trump subjected E. Jean Carroll to sexual contact without her consent, by the use of force, for the purpose of sexual gratification. The specific factual finding the jury made — recorded on the verdict form — was that Trump non-consensually penetrated Carroll's vagina with his fingers in a Bergdorf Goodman dressing room in late 1995 or early 1996.

The jury did not find Trump liable for rape under New York's narrow legal definition, which at the time of the act required penile penetration. Judge Lewis A. Kaplan, presiding, later issued a written clarification that addressed this distinction directly. Kaplan wrote that the jury's finding of digital penetration constituted rape "as many people commonly understand the word." The narrowness of New York's penile-only definition, Kaplan wrote, did not negate the substance of what the jury found Trump had done.

The jury also found Trump liable for defamation — specifically, for statements Trump made in October 2022 calling Carroll's account a hoax and her a liar. The defamation finding was made under the actual-malice standard, which requires a showing that the defendant knew the statement was false or made it with reckless disregard for its truth.

The jury awarded Carroll $5 million in compensatory and punitive damages. Trump appealed. The Second Circuit affirmed the verdict, and on June 29, 2026 the Supreme Court declined to hear Trump's appeal — exhausting his appeals and making the judgment final; the award, with interest, was paid to Carroll in July 2026.

Carroll I — January 2024

The second Carroll trial concerned an earlier set of defamatory statements — the ones Trump made from the White House in June 2019, while he was the sitting President of the United States, after Carroll first published her account of the 1996 assault in New York magazine.

In those 2019 statements, Trump said he had never met Carroll, that she was "not my type," and that her account was a fabrication designed to sell books. Carroll sued for defamation. Because Trump had made the statements while in office, the case was delayed for years by litigation over whether his statements had been within the scope of his federal employment — a question that, if answered yes, would have substituted the United States as defendant.

The Second Circuit eventually ruled the statements had not been within the scope of his employment. The case proceeded against Trump personally. By the time of trial in January 2024, the Carroll II jury had already found that the underlying assault occurred — collaterally estopping Trump from re-litigating that question.

The Carroll I jury awarded Carroll $83.3 million. The award included $7.3 million in compensatory damages for emotional harm and reputational damage, $11 million for the cost of a reputational repair program, and $65 million in punitive damages — the largest single component, calibrated by the jury to the scale of the platform from which the defamation was issued.

The size of the punitive award is the part of Carroll I that is doing the structural work. The jury was telling Trump, and recording for the public ledger, that a sitting president using the presidential platform to defame a sexual-assault survivor in order to protect his political position is a category of harm that warrants damages on the order of magnitude of the platform itself. The defamation was not ordinary defamation. It was state-amplified defamation, delivered from the most powerful podium on earth to a private citizen who had described what he had done to her. The jury priced the harm accordingly.

Federal Rules of Evidence 413 and 415

The Carroll II verdict was made possible in part by two federal rules of evidence that are rarely invoked outside of sexual-assault civil litigation. Federal Rule of Evidence 413 permits, in a criminal case in which a defendant is accused of a sexual assault, the admission of evidence that the defendant committed any other sexual assault. Rule 415 extends the same admissibility to civil cases.

The default presumption in federal civil litigation is that propensity evidence — evidence offered to show that a defendant acted in conformity with prior conduct — is inadmissible. Rules 413 and 415 are exceptions, written into the Federal Rules in 1995, in recognition of the specific evidentiary problem that sexual-assault cases pose: the conduct typically occurs in private, without witnesses, often years before disclosure, and the question for the factfinder is fundamentally one of pattern and credibility.

Judge Kaplan granted the Carroll plaintiffs' motion to admit prior-conduct evidence under Rule 415. The jury heard testimony from Jessica Leeds, who described being groped by Trump on a flight in the early 1980s. The jury heard testimony from Natasha Stoynoff, who described being forced against a wall and kissed by Trump during a 2005 People magazine interview at Mar-a-Lago. The jury also heard the Access Hollywood tape itself, played in full, as evidence of Trump's own description of the pattern of conduct of which Carroll's account was an instance.

This is the clinical-evidence analog the legal system has built for exactly this category of harm. In a clinical setting, pattern is the diagnosis. A single complaint of inappropriate contact is data. Three or four complaints of the same pattern from independent reporters across decades, with no contact among the reporters, is a finding. Rules 413 and 415 are the legal system's recognition that the same epistemics apply in court. The Carroll jury was permitted to reason from pattern. They did.

The 28 — pattern, not roster

At least 28 women have publicly described non-consensual sexual contact by Donald Trump. The accounts cluster, by setting, into five environments. I am not going to enumerate all 28. I am going to describe the clusters and select the tightest accounts from each, because the pattern is what is doing the work, not the count.

Airline and business associate. Jessica Leeds, early 1980s, on a flight to New York: Trump lifted the armrest of her first-class seat about forty-five minutes into the flight and, as she later described it, was "like an octopus" — hands on her breasts, hands attempting to reach up her skirt. She moved to coach. She came forward in 2016 after watching Trump deny on the debate stage that he had ever done any such thing. Jill Harth, 1992–1993, business associate: groped under a table at the Plaza Hotel during a dinner; in January 1993 at Mar-a-Lago, by Harth's account, Trump pulled her into an empty bedroom during a tour and pinned her against a wall, groping her "intimate private parts" and attempting to kiss her. Harth filed a $125 million sexual harassment lawsuit in 1997. The suit was withdrawn after her partner reached a separate settlement with Trump.

Department store and nightclub. E. Jean Carroll, late 1995 or early 1996, Bergdorf Goodman, the lingerie department. Trump asked her help in choosing a gift. He led her to a dressing room. He slammed her against the wall, pinned her down, forcibly penetrated her. She told two friends contemporaneously. She did not go to police. She published in 2019. The jury found for her in 2023. Kristin Anderson, early 1990s, the China Club in Manhattan: Trump reached under her skirt and touched her vagina through her underwear while she sat with friends.

Beauty pageant. Samantha Holvey, Miss USA 2006, on Trump's "inspection" of the contestants: "He just came strolling right in. There was no second to put a robe on or any sort of clothing or anything. Some girls were topless, other girls were naked." Holvey described Trump inspecting the contestants "like meat." Tasha Dixon, Miss USA 2001: "He just came strolling right in… Our first introduction to him was when we were at the dress rehearsal and half naked changing into our bikinis." Bridget Sullivan, Miss USA 2000: witnessed Trump walking through dressing rooms while contestants were naked. Cassandra Searles, Miss Washington 2013: alleged that Trump grabbed her buttocks repeatedly during the pageant and invited her to his hotel room. Multiple anonymous contestants from the 1997 Miss Teen USA pageant — featuring contestants as young as fifteen — described Trump entering their dressing room while they were undressed.

Reality TV and corporate. Summer Zervos, 2007, former Apprentice contestant: alleged that during meetings ostensibly about job opportunities — at Trump Tower and later a Beverly Hills hotel — Trump aggressively kissed her, grabbed her breast, and thrust his genitals against her. Zervos filed a defamation suit in 2017 after Trump called her a liar. She settled in 2021 without compensation. Natasha Stoynoff, 2005, People magazine reporter: was at Mar-a-Lago to interview Trump and Melania for their first wedding anniversary. Stoynoff alleged Trump lured her into a private room, shut the door, pushed her against a wall, and forced his tongue down her throat. She described going into "freeze." Rachel Crooks, 2005, twenty-two years old, receptionist for the Bayrock Group in Trump Tower: introduced herself to Trump outside an elevator; Trump kissed her on the cheeks and then, in her words, "kissed me directly on the mouth."

Modeling. Amy Dorris, 1997, U.S. Open VIP box: alleged Trump accosted her outside a bathroom, forced his tongue down her throat, and groped her body so tightly she could not escape. Dorris provided contemporaneous photos and travel records placing her with Trump at the time. Beatrice Keul, 1993, Swiss model: alleged Trump groped her in his suite at the Plaza Hotel. Stacey Williams, 1993, model: alleged that Jeffrey Epstein brought her to Trump Tower; Trump pulled her to him and groped her breasts, waist, and buttocks while, as Williams describes it, the two men smiled at each other.

The Access Hollywood tape — 2005

In September 2005, Donald Trump and television host Billy Bush were recorded on a bus arriving at the set of Days of Our Lives, where Trump was filming a cameo. The recording was made on an open microphone. It was released by The Washington Post on October 7, 2016, one month before the presidential election. Trump described, in his own voice, his approach to women.

"I just start kissing them. It's like a magnet. Just kiss. I don't even wait."
"When you're a star, they let you do it. You can do anything."
"Grab 'em by the pussy. You can do anything."

In 2017, after multiple women had come forward describing the same pattern, Billy Bush wrote an op-ed in The New York Times confirming the tape's authenticity. Bush wrote that he and the other men on the bus had treated Trump's comments as "a crass standup act" at the time, and that the public allegations from women that followed had forced him to recognize that the conduct Trump was describing was conduct Trump had been engaged in.

In the Carroll trial, Carroll's counsel used the Access Hollywood tape in summation as a verbal blueprint for what Trump had been found to have done to Carroll. Trump had described, on tape, in his own voice, a specific modus operandi: sudden physical advance without warning, the assertion that fame conferred consent, non-consensual genital contact characterized as something women "let you do." Carroll had described, on the stand, that exact sequence — sudden physical advance, no warning, the assertion of authority, non-consensual penetration. The jury heard the tape and Carroll's account in the same week. They returned a verdict consistent with what they had heard.

The dressing rooms — 1997 through 2013

Trump bought the Miss Universe Organization, which owned the Miss USA and Miss Teen USA pageants, in 1996. Over the next seventeen years — through 2015, when the Univision and NBC partnerships ended and Trump sold the organization — multiple contestants and staff described a recurring practice in which Trump entered the contestants' dressing rooms while they were in various states of undress.

Trump described the practice himself, in his own voice, in a 2005 interview on The Howard Stern Show:

"I'll go backstage before a show and everyone's getting dressed and ready and everything else. And, you know, no men anywhere. And I'm allowed to go in because I'm the owner of the pageant and therefore I'm inspecting it. You know, I'm inspecting because I want to make sure that everything is good. You know, the dresses. 'Is everyone OK?' You know, they're standing there with no clothes. And you see these incredible-looking women. And so I sort of get away with things like that."

The phrasing is the documentary record. I sort of get away with things like that. Trump, in 2005, described the practice as something he was getting away with — language that internally acknowledges the practice's wrongfulness and characterizes it as enabled by his ownership of the pageant.

The contestants who came forward over the following years described the practice as Trump had described it. Tasha Dixon told CBS Los Angeles in 2016 that Trump "just came strolling right in" to the dressing room during Miss USA 2001 dress rehearsals. A second 2001 contestant, who remained anonymous, told The Guardian that Trump "stared at us because he knew that we could not cover up." Samantha Holvey, Miss USA 2006, described the inspection as something contestants understood they were expected to perform compliance with — "like meat." Multiple contestants from the 1997 Miss Teen USA pageant — at which contestants ranged from fifteen to nineteen years old — described Trump entering the dressing room while they were undressed.

The structural point is ownership. The contestants did not have the option to decline the inspection. The owner of the pageant entered. The owner of the pageant said so himself on Howard Stern's show. The owner of the pageant characterized it as something he got away with.

Ivana — 1989

In 1990, during her divorce proceedings against Donald Trump, Ivana Trump gave a sworn deposition describing an incident from 1989. The deposition described an attack in the master bedroom of the Trump Tower triplex, following a scalp-reduction surgery Trump had undergone and for which he blamed Ivana for recommending the surgeon. Ivana described being attacked physically by her husband and forced into sexual contact against her will. In the deposition, she used the word "rape."

The deposition was sealed as part of the 1992 divorce settlement. The account became public in 1993 when journalist Harry Hurt III obtained the deposition for his book Lost Tycoon. At that point, in a 1993 statement issued as part of the settlement agreement, Ivana clarified that she had "felt violated" and that the "love and tenderness" normally in their relationship had been absent, but that she did not want her use of the word "rape" to be interpreted "in a literal or criminal sense."

The 1993 clarification is what is typically cited by Trump's defenders. The original 1990 deposition is what is typically cited by the press. Both are part of the record. The court granted the divorce on grounds of "cruel and inhuman" treatment. Ivana Trump died in 2022.

The reason this 1989 incident belongs in the adjudicated-record companion is the same reason the 1993 Stacey Williams account belongs here, and the same reason Williams was already discussed in Part One. Both accounts predate the Carroll assault by years. Both fit the pattern of conduct that Rules 413 and 415 allowed the Carroll jury to consider. Stacey Williams' account, as Williams describes it, also contains the specific feature that connects this companion's two halves — the presence of Jeffrey Epstein, watching, smiling.

What the adjudicated record shows is this. A federal jury, applying a preponderance-of-the-evidence standard, found that Donald Trump sexually abused E. Jean Carroll. A second federal jury awarded Carroll $83.3 million for the defamation Trump committed in 2019 from the White House podium. The Second Circuit affirmed. Twenty-six other women have publicly described conduct consistent in pattern with what the Carroll jury found. Two of them — Jessica Leeds and Natasha Stoynoff — testified at the Carroll trial under Federal Rule of Evidence 415, which the federal system has built specifically to allow factfinders to reason from pattern in sexual-assault cases. Trump's own voice, on the Access Hollywood tape and on Howard Stern's show, described the pattern in language the jury was able to compare to the testimony in front of them.

Then, in November 2024, eighteen months after the Carroll II verdict, seventy-six million Americans cast votes to return Donald Trump to the presidency.

This is what the book is about. It is what every chapter has been circling. We have the record. The record is in federal court filings. The record is in two jury verdicts. The record is in the tape Trump made of himself in 2005. The record is in the Howard Stern transcript. The record is in twenty-eight publicly named women whose accounts, taken together, describe the same pattern with such consistency that the federal rules of evidence permit a factfinder to reason from one to the next. The record was on the table in 2024. The electorate read it and returned a verdict of their own.

That verdict is the subject of Chapter 5 of More True and More FalseThey Knew. And They Didn't Care. The chapter is not about Donald Trump. It is about the structural fact that the documented and adjudicated record of sexual abuse against women — including against girls; including across four decades; including, in the Carroll cases, established in federal court — has been demonstrated, in this country, to be insufficient to disqualify a candidate for the highest office. That is not a finding about Donald Trump. That is a finding about us.

Part One of this companion was about the shorter record — Donald Trump's documented proximity to Jeffrey Epstein's operation, over fifteen years, with intervals where intervention was possible and did not happen. Part Two has been about the longer record — the conduct, established in federal court and described by twenty-eight women, that Donald Trump's own voice on tape predicts and explains. Both pieces are the same finding from two angles. The pattern is documented. The harm is documented. The system that produced and protected the pattern is documented. The electorate that, in possession of all of this, returned the principal of the documented pattern to the highest office in the country is the finding the book is trying to name.

In a clinical chart, this is where the assessment goes. The assessment is that a clinical population that does this to its girls is not safe for its girls. The treatment plan, such as it exists, is the work this book is part of: keep the chart, refuse to lose the record, name the finding plainly, and refuse to let the political environment around the finding alter what the finding is.