Paula Corbin Jones v. William J. Clinton
72 F.3d 1354 (1996)
Premium Feature
Subscribe to Lexplug to listen to the Case Podcast.
Rule of Law:
A sitting President of the United States is not entitled to temporary immunity from civil liability for unofficial acts committed in a personal capacity, and such lawsuits may proceed under judicial case management to accommodate presidential duties.
Facts:
- On May 8, 1991, while William Jefferson Clinton was governor of Arkansas, Paula Corbin Jones was a state employee.
- An incident occurred in a Little Rock, Arkansas, hotel suite between William Jefferson Clinton and Paula Corbin Jones.
- Paula Corbin Jones alleged that William Jefferson Clinton sexually harassed and assaulted her, violating her constitutional rights to equal protection and due process.
- Paula Corbin Jones further alleged that William Jefferson Clinton and Trooper Danny Ferguson conspired to violate those rights.
- Paula Corbin Jones also brought supplemental state law claims against William Jefferson Clinton for intentional infliction of emotional distress and against both William Jefferson Clinton and Trooper Danny Ferguson for defamation.
Procedural Posture:
- On May 6, 1994, Paula Corbin Jones filed suit in the U.S. District Court for the Eastern District of Arkansas against William Jefferson Clinton and Arkansas State Trooper Danny Ferguson.
- William Jefferson Clinton filed a motion to dismiss the complaint, asserting immunity from civil suit, or in the alternative, for a stay of the proceedings for the duration of his presidency.
- On December 28, 1994, the District Court denied William Jefferson Clinton's motion to dismiss the complaint, rejecting the application of absolute immunity.
- The District Court granted William Jefferson Clinton's request to stay the trial for the duration of his presidency, finding that for separation of powers reasons, he was entitled to 'temporary or limited immunity from trial'.
- The District Court also stayed the trial against Trooper Ferguson, concluding the claims against him were factually and legally intertwined with those against William Jefferson Clinton, but permitted discovery to proceed against both defendants.
- William Jefferson Clinton (appellant) appealed the District Court's rejection of his motion to dismiss and its decision to allow discovery to proceed.
- Paula Corbin Jones (cross-appellant) cross-appealed the District Court's decision to stay the trial of her claims against both William Jefferson Clinton and Trooper Ferguson.
Premium Content
Subscribe to Lexplug to view the complete brief
You're viewing a preview with Rule of Law, Facts, and Procedural Posture
Issue:
Does a sitting President of the United States enjoy temporary immunity from civil lawsuits alleging unofficial conduct, thereby requiring such suits to be dismissed without prejudice or stayed for the duration of the presidency?
Opinions:
Majority - BOWMAN, Circuit Judge
No, a sitting President of the United States is not entitled to immunity from civil suits for unofficial acts, and such suits should not be stayed for the duration of the presidency. The Court held that the absolute immunity recognized in Nixon v. Fitzgerald for official acts does not extend to unofficial acts, which fall outside the 'outer perimeter' of presidential responsibility. The Constitution does not grant the President sovereign immunity, and the separation of powers doctrine, while justifying immunity for official acts to protect presidential decision-making, is 'inapposite' where only personal, private conduct is at issue. Concerns about potential disruption to presidential duties are to be addressed through appropriate judicial case management, allowing courts to control scheduling and grant continuances as needed, rather than by granting an unconstitutional temporary immunity from suit.
Dissenting - ROSS, Circuit Judge
Yes, private actions for damages against a sitting President, even for unofficial acts, must be stayed until the completion of the President's term, unless exigent circumstances can be shown. The dissent argued that the rationale of Nixon v. Fitzgerald, particularly concerns about the 'diversion of energies' and the potential for harassment and extortion, applies with equal force to unofficial acts. Defending any civil lawsuit, regardless of its nature, would place significant burdens on the President's time and attention, thus impairing the 'singular importance' of the President's constitutional responsibilities and creating opportunities for unconstitutional judicial intrusion on the Executive Branch. A stay, including pretrial discovery, is necessary to avoid such conflicts and protect the public interest in the President's unimpaired performance of duties, while merely delaying rather than defeating the plaintiff's claims.
Concurring - BEAM, Circuit Judge
No, a sitting President is not entitled to a blanket stay of civil litigation for unofficial acts. While acknowledging separation of powers concerns, the concurrence emphasized the substantial prejudice a stay, particularly one precluding discovery, would inflict upon the plaintiff, Paula Corbin Jones, including the loss of evidence due to death or incompetence of parties or witnesses, and the extinguishment of certain claims like defamation under applicable state law. Access to the courts and the timely vindication of civil rights are 'fundamental constitutional right[s]' that serve a significant public interest. Historical examples demonstrate that Presidents have managed to participate in legal proceedings without compromising their constitutional duties. Therefore, judicial case management is the appropriate solution, placing the burden on the President to show specific hardship for any requested delay, rather than imposing insurmountable requirements on the plaintiff.
Analysis:
This case significantly narrowed the scope of presidential immunity, drawing a critical distinction between official and unofficial acts. By denying immunity for unofficial conduct, the court affirmed the principle that the President, like all citizens, is subject to the law for personal wrongs, reinforcing accountability. The ruling shifted the burden from requiring plaintiffs to demonstrate 'urgency' to allowing courts to manage litigation schedules, impacting future cases by providing a framework for civil suits against sitting presidents while attempting to safeguard executive functions. It also highlighted the importance of balancing executive independence with individual access to justice.
