Nixon v. United States
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Overview
Overview
The Supreme Court held that the Senate's impeachment trial procedures are not subject to judicial review.
The Facts
Facts
President Richard Nixon was impeached by the House of Representatives in 1974 on charges of obstruction of justice, abuse of power, and contempt of Congress related to the Watergate scandal. Facing near-certain conviction in the Senate, Nixon resigned on August 9, 1974. The case arose when Nixon challenged the Senate's impeachment procedures after his resignation.
The Issue
Issue
Whether the Senate's judgment in an impeachment trial, including its procedural rules for trying impeachments, constitutes a nonjusticiable political question committed exclusively to the Senate by Article I's grant of the 'sole Power to try all Impeachments.' Whether the President's assertion of executive privilege prevents the Special Prosecutor's grand jury subpoena for White House tape recordings, and whether courts may adjudicate that dispute.
The Rules
Rule
Nixon v. United States, 506 U.S. 224 (1993), held that the Senate's method of conducting an impeachment trial is a nonjusticiable political question because the Constitution's grant to the Senate of the 'sole Power to try all Impeachments' commits the matter to the Senate without judicially manageable standards. United States v. Nixon, 418 U.S. 683 (1974), held that neither the doctrine of separation of powers nor executive privilege provides an absolute shield against a specific, concrete, and particularized subpoena for evidence in a criminal proceeding. The President's generalized interest in confidentiality must yield to the demonstrated, specific need for evidence in the criminal justice process.
The Application
Analysis
When President Nixon challenged the Senate's impeachment procedures after his resignation, the Court held that his challenge presented a nonjusticiable political question. The Constitution's textual grant to the Senate of the "sole Power to try all Impeachments" commits that function exclusively to the legislative branch without establishing judicially manageable standards for reviewing the Senate's procedural choices. Allowing courts to adjudicate impeachment procedures would violate separation of powers by intruding upon a power the Constitution explicitly reserved to Congress. Therefore, the Court held that the Senate's method of conducting impeachment trials is beyond judicial review.
The Conclusion
Conclusion
The Supreme Court held 9-0 that impeachment trials are not subject to judicial review, establishing that the impeachment clause contains a textual commitment of issues to a coordinate political department rendering them nonjusticiable. The Court found that judicial review of impeachment procedures would violate the separation of powers by intruding upon Congress's sole power to try impeachments.
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