U.S. District Judge Lewis A. Kaplan made the determination in an order in advance of a Jan. 16 trial to determine defamation damages against Trump after a jury concluded Trump sexually abused columnist E. Jean Carroll but did not find evidence was sufficient to conclude that he raped her.

Trump, speaking in Iowa on Saturday as the Republican frontrunning presidential candidate in advance of a Jan. 15 primary, criticized the judge as a “radical Democrat” and mocked E. Jean Carroll for not screaming when she was attacked. “It was all made up,” he said.

Carroll, 80, won a $5 million award last May from a jury that concluded Trump sexually abused her in 1996 in a luxury department store dressing room and defamed her in 2022.