Nixon v. United States
506 U.S. 224 (1993)
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Rule of Law:
The constitutionality of the Senate's impeachment trial procedures is a nonjusticiable political question that the federal courts may not review. The Impeachment Trial Clause textually and structurally commits the sole power to try all impeachments to the Senate.
Facts:
- Walter L. Nixon, Jr., a Chief Judge for the U.S. District Court for the Southern District of Mississippi, was investigated for accepting an illegal gratuity from a businessman.
- A federal grand jury indicted Nixon for making false statements to them during the course of the investigation.
- Following a criminal trial, Nixon was convicted on two counts of making false statements to the grand jury and was sentenced to prison.
- Nixon refused to resign his judicial office after his conviction and continued to collect his judicial salary while serving his prison sentence.
- The U.S. House of Representatives adopted three articles of impeachment against Nixon for high crimes and misdemeanors.
- Pursuant to Senate Rule XI, the Senate appointed a committee of Senators to receive evidence and take testimony in Nixon's impeachment case.
- The committee held hearings and then presented a complete transcript and a report summarizing the evidence to the full Senate.
- After briefs and oral arguments were presented to the full Senate, the Senate voted by more than a two-thirds majority to convict Nixon on two articles and remove him from office.
Procedural Posture:
- After being convicted and removed from office by the U.S. Senate, Walter L. Nixon, Jr. filed suit in the U.S. District Court for the District of Columbia.
- Nixon sought a declaratory judgment that his impeachment conviction was void and that he should be reinstated with back pay.
- The District Court, a court of first instance, held that Nixon's claim was nonjusticiable and dismissed the suit.
- Nixon, as appellant, appealed to the U.S. Court of Appeals for the District of Columbia Circuit.
- The Court of Appeals, an intermediate appellate court, affirmed the District Court's judgment, agreeing that the claim was nonjusticiable.
- The U.S. Supreme Court granted Nixon's petition for a writ of certiorari.
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Issue:
Is a federal judge's claim that Senate Rule XI, which allows a committee to hear evidence in an impeachment proceeding, violates the Impeachment Trial Clause's grant of power to the Senate to 'try' all impeachments, a nonjusticiable political question?
Opinions:
Majority - Chief Justice Rehnquist
Yes, this claim presents a nonjusticiable political question. The Impeachment Trial Clause (Art. I, §3, cl. 6) contains a 'textually demonstrable constitutional commitment of the issue to a coordinate political department.' The clause states the Senate shall have the 'sole' Power to try all impeachments. The word 'sole' signifies that this authority is reposed in the Senate alone and excludes other branches, including the judiciary. Furthermore, the claim presents a 'lack of judicially discoverable and manageable standards' because the word 'try' is not precise enough to provide a textual limit on the Senate's methods. The Constitution specifies three precise requirements for impeachment trials (oath, two-thirds vote, Chief Justice presides for President), suggesting the Framers did not intend other, unstated procedural limits. Judicial review would also undermine the impeachment's function as the sole legislative check on the judiciary and would create political chaos by preventing finality in impeachment judgments.
Concurring - Justice Stevens
Yes, this claim is nonjusticiable. The central fact is that the Framers deliberately assigned the impeachment power to the Legislative Branch. A wise policy of judicial restraint and respect for a coordinate branch of government, coupled with the potential for chaos that judicial review would create, justifies the conclusion that courts should not intervene in the Senate's exercise of this power.
Concurring - Justice White
No, this claim is justiciable, but the Senate's procedure is constitutional. The political question doctrine does not bar courts from interpreting the Constitution, including the word 'try,' which has a judicially manageable meaning. However, the Senate's use of a committee to take evidence does not violate its constitutional obligation to 'try' the impeachment. The Framers did not intend to bind the Senate to specific trial procedures beyond those explicitly listed, giving it discretion to determine its own rules. Therefore, while the Court should have reached the merits, the judgment to affirm the lower court is correct because Nixon's claim fails.
Concurring - Justice Souter
Yes, this case presents a nonjusticiable political question, primarily for prudential reasons. While the Senate has broad discretion, judicial review might be appropriate in a hypothetical case where the Senate's actions were so far beyond its authority as to threaten the integrity of its results, such as convicting based on a coin toss. However, this case does not present such an extreme circumstance, and the need for finality and respect for a coordinate branch counsels against judicial intervention here.
Analysis:
This decision firmly establishes that the Senate's internal procedures for impeachment trials are immune from judicial review under the political question doctrine. By focusing on the word 'sole' in the Impeachment Trial Clause, the Court reinforced a strong separation of powers, treating impeachment as an exclusively political process committed to the legislature. The ruling gives the Senate vast discretion in structuring impeachment trials, significantly limiting any potential for judicial oversight. This precedent is crucial in any impeachment discussion, as it confirms that the only recourse against the Senate's procedural choices lies within the political process itself, not in the courts.
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