As of September 2026, two Trump appeal bonds are still worth tracking, and only one of them is still doing any work. The New York civil fraud undertaking — $175 million, posted 1 April 2024 — became reclaimable after an appeals court struck the penalty it secured, while the E. Jean Carroll defamation bond has been raised to roughly $99.1 million and remains posted while the Supreme Court decides whether to hear the case.
An appeal bond, also called a supersedeas bond or undertaking, is a guarantee filed by a losing defendant that freezes the winner's ability to collect while an appeal runs. It is not a payment and not a fine. It is collateral that says the money will be there if the verdict survives — and in both of these cases, it is the reason no cash has changed hands on judgments first entered in 2024.
Table of Contents
- Where each bond stands right now
- What is still unresolved in the New York fraud case
- The Carroll appeal and the Supreme Court timetable
- One piece is finished and cannot be reopened
- Why the bond exceeds the verdict — and what it costs
- Questions to ask when reading coverage of an appeal bond
- Frequently Asked Questions
Where each bond stands right now
The civil fraud bond came out of New York Attorney General Letitia James's case before Justice Arthur Engoron. The Appellate Division, First Department, cut the required undertaking from the full $464 million judgment to $175 million on 25 March 2024 and gave Trump ten days; NBC News reported that he posted it on 1 April 2024 through Knight Specialty Insurance Co., a Hankey Group unit not licensed to write surety in New York. That bond's job effectively ended on 21 August 2025. As NPR reported, the First Department voided the roughly $500 million disgorgement penalty as "an excessive fine that violates the Eighth Amendment." With no money judgment left to secure, Trump became eligible to reclaim the $175 million.
The Carroll bond is the live one. Trump posted $91,630,000 from Federal Insurance Co., a Chubb unit, on 8 March 2024 — 110% of the $83.3 million verdict, sized for New York's 9% post-judgment interest — and Judge Lewis Kaplan approved it, staying collection. According to NBC News, the Second Circuit later allowed continued deferral until the Supreme Court acts, on the condition that Trump raise the bond by $7,462,492.74, to about $99.1 million, to cover interest accruing through October. Carroll did not oppose the delay on that condition.
What is still unresolved in the New York fraud case
Striking the penalty did not end the case. The First Department left the fraud liability finding standing, along with Engoron's injunctive relief — and that relief is what still constrains the Trump Organization. Courthouse News reported that the dispute is now before the New York Court of Appeals, the state's highest court, where Trump filed a 119-page brief asking that the liability finding and the remaining restrictions be thrown out.
That brief answers James's own appeal, which asks the court to restore the voided penalty. Both directions are on the table: the money could come back, or the findings could go away. Still in force meanwhile are a three-year ban on Trump and his two eldest sons leading New York businesses, and a three-year bar on obtaining loans from New York-registered financial institutions. Those are the practical stakes of the state appeal, not the headline dollar figure.
The Carroll appeal and the Supreme Court timetable
The Second Circuit affirmed the $83.3 million judgment on 8 September 2025 in *Carroll v. Trump*, No. 24-644, calling the $18.3 million compensatory and $65 million punitive awards "fair and reasonable." It rejected the presidential-immunity defense as both inapplicable and waived — meaning the argument did not fit the facts and had not been preserved in time. On 28 July 2026, Trump petitioned the Supreme Court in No. 26-141, and the Justice Department filed a parallel petition — *United States v.
Carroll*, No. 26-142 — arguing the government should be substituted as defendant because the statements were made while he was president, per SCOTUSblog. Substitution matters more than it sounds: if the United States became the defendant, the individual judgment against Trump would not stand as it does now. The Court's next term opens in October 2026. The practical deadline readers should watch is not a payment date but a docket event: an order granting or denying certiorari in 26-141 and 26-142. A denial ends the stay and the bond becomes the collection source; a grant extends the freeze into merits briefing.
One piece is finished and cannot be reopened
The earlier, separate $5 million Carroll verdict is over. SCOTUSblog reported that the Supreme Court denied certiorari in No. 25-573 on 29 June 2026 and refused rehearing in August 2026.
📨 Get Free Accountability Coverage Alerts
Free · No spam · Unsubscribe anytime
Carroll has already been paid. That limitation matters for anyone reading the two cases as one story. A win in 26-141 would not reopen the $5 million judgment, claw that money back, or unwind the underlying findings in that trial. The two verdicts came from separate proceedings and are on separate tracks.
Why the bond exceeds the verdict — and what it costs
None of this is a Trump-specific rule. New York's CPLR 5519(a)(2) stays enforcement automatically once a money-judgment appellant files an undertaking. That is the whole mechanism: file the bond, collection stops, no judicial discretion required.
It also explains the arithmetic. Interest runs on a judgment during the appeal, so a bond sized only to the verdict would fall short by the time the appeal ends. Hence 110% at the start, and hence the $7.46 million top-up the Second Circuit demanded before extending the Carroll stay. For any judgment debtor, the trade is the same shape:.
- A bond buys time; it does not reduce the judgment.
- Surety premium typically runs 1–2% of the bond amount per year, on top of accruing interest.
- Sureties generally require collateral — often cash or a letter of credit — for most or all of the face amount.
- The bond must be topped up if the appeal outlasts the interest cushion built into it.
- Check whether the surety is licensed in the state where the bond is filed; the fraud bond drew objections on exactly that point.
Questions to ask when reading coverage of an appeal bond
.
- Which judgment does this bond secure? Two bonds in two cases are not interchangeable, and one may already be released.
- Has the underlying judgment been affirmed, reduced, or vacated? A vacated penalty frees the bond; an affirmed one turns the bond into the payment source.
- Is the stay automatic under statute, or discretionary from the appellate court? The Carroll extension was conditional and required more money; the original CPLR filing was not.
- Is the bond amount current? A figure reported in 2024 may be stale by the interest top-up alone.
- What is actually being appealed — the dollars, the liability finding, or the non-monetary restrictions? In the New York fraud case, the business-leadership ban and the loan bar survived the penalty being struck.
Frequently Asked Questions
Does posting a bond mean the judgment is paid?
No. The bond is collateral held by a surety. It only converts into payment if the appeal fails and the judgment stands.
Who gets the $175 million now?
With the disgorgement penalty voided in August 2025, Trump became eligible to reclaim it. The bond secured a penalty that no longer exists — though the Attorney General's appeal asks the Court of Appeals to restore it.
Could the Supreme Court cut the $83.3 million award rather than erase it?
The Second Circuit already reviewed the amount and called it fair and reasonable. The petitions at the Court press immunity and government substitution, not the size of the award.
Why did Carroll agree to another delay?
She did not oppose it on the condition set by the Second Circuit — that the bond rise by $7,462,492.74, covering interest through October, so waiting costs her nothing.
You Might Also Like
- Trump Science 2026 Guide: status, deadlines, and legal impact; Key Facts and Questions to Ask
- Trump Pharma 2026 Guide: status, deadlines, and legal impact; Key Facts and Questions to Ask
- Trump Medicare 2026 Guide: status, deadlines, and legal impact; Key Facts and Questions to Ask