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Trump v. Mazars USA, LLP

Supreme Court of the United States
591 U. S. ____ (2020) (2020)
ELI5:

Rule of Law:

When Congress subpoenas a sitting President's personal information for a legislative purpose, courts must apply a balancing test that weighs Congress's significant interests against the unique separation of powers concerns implicated. This analysis requires assessing whether the legislative purpose warrants involving the President's papers, the subpoena's breadth, the substance of Congress's stated purpose, and the burdens placed on the President.


Facts:

  • In April 2019, the U.S. House Committee on Financial Services issued subpoenas to Deutsche Bank and Capital One for extensive financial records of President Donald J. Trump, his children, and their businesses.
  • The Committee stated the records were needed for its investigation into potential legislative reforms concerning money laundering, terrorism financing, and corruption.
  • On the same day, the House Permanent Select Committee on Intelligence issued a subpoena to Deutsche Bank for similar records, asserting they were part of an investigation into foreign efforts to undermine the U.S. political process.
  • Four days later, the House Committee on Oversight and Reform issued a subpoena to Mazars USA, LLP, President Trump’s accounting firm, for statements of financial condition and other documents.
  • The Oversight Committee claimed the documents were necessary to investigate potential undisclosed conflicts of interest, compliance with the Emoluments Clauses, and the accuracy of the President's financial disclosures.
  • The subpoenas sought non-privileged, personal and corporate records, not official documents related to the President's executive duties.

Procedural Posture:

  • President Trump, his family, and affiliated businesses filed two lawsuits in separate federal district courts to obtain injunctions preventing compliance with the subpoenas.
  • The lawsuit challenging the Oversight Committee's subpoena to Mazars was filed in the U.S. District Court for the District of Columbia.
  • The D.C. District Court granted judgment for the House Committee, upholding the subpoena.
  • President Trump, the appellant, appealed to the U.S. Court of Appeals for the D.C. Circuit, which affirmed the district court's decision in favor of the House, the appellee.
  • The lawsuit challenging the subpoenas to Deutsche Bank and Capital One was filed in the U.S. District Court for the Southern District of New York.
  • The S.D.N.Y. District Court denied President Trump's motion for a preliminary injunction.
  • President Trump, the appellant, appealed to the U.S. Court of Appeals for the Second Circuit, which also affirmed the lower court's decision in favor of the House Committees, the appellees.
  • President Trump petitioned the U.S. Supreme Court for a writ of certiorari in both cases, which was granted.

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Issue:

Do congressional subpoenas seeking the personal financial records of a sitting President from third-party custodians exceed the authority of the House of Representatives under the Constitution's separation of powers?


Opinions:

Majority - Chief Justice Roberts

Yes, as validated by the lower courts, the subpoenas exceed congressional authority because the courts failed to adequately account for the separation of powers. Congressional subpoenas for a sitting President's personal papers require a careful balancing test that considers both Congress's legislative needs and the unique status of the President. The Court rejected both the President's argument for a heightened "demonstrably critical" standard (derived from executive privilege cases) and the House's argument that a subpoena is valid as long as it serves any legitimate legislative purpose. Instead, courts must apply a new four-factor analysis: (1) assess whether the legislative purpose warrants the significant step of involving the President and his papers, particularly whether the information is available from other sources; (2) insist that the subpoena is no broader than reasonably necessary; (3) consider the nature and specificity of the evidence offered by Congress to establish its legislative purpose; and (4) carefully assess the burdens a subpoena imposes on the President. Because the lower courts did not conduct this analysis, their judgments are vacated and the cases are remanded.


Dissenting - Justice Thomas

Yes, the subpoenas exceed congressional authority because Congress has no power to issue a legislative subpoena for a President's private, nonofficial documents. The historical powers of the British Parliament are not analogous to Congress's limited, enumerated powers. The Constitution provides a specific mechanism for investigating potential wrongdoing by the President: the power of impeachment. Allowing Congress to use its general legislative authority to probe the President's private affairs outside of impeachment usurps a judicial function and upsets the constitutional structure. Therefore, the subpoenas are invalid, and the Court should not have created a new balancing test but should have reversed the lower courts outright.


Dissenting - Justice Alito

Yes, the subpoenas as currently justified exceed congressional authority, and while the case should be remanded, the majority's test is inadequate. Legislative subpoenas for a President's personal documents are inherently suspicious and require a more demanding showing from Congress than the majority's test outlines. Congress should be required to specifically identify the type of legislation being considered, its constitutional authority to enact such legislation, and a detailed justification for the scope of the documents sought and why they are necessary over information from other sources. Because the Court's remand instructions are not sufficiently stringent to protect the separation of powers, the framework is inadequate.



Analysis:

This case establishes a new and significant precedent for resolving disputes over congressional subpoenas for a sitting President's personal information. By rejecting the categorical approaches favored by both the President and the House, the Court created a flexible, context-specific balancing test. This decision ensures that neither branch has unchecked power; Congress cannot use its oversight authority as a boundless tool to harass the President, and the President cannot use his office to categorically shield his personal affairs from legitimate legislative inquiry. The ruling moves these disputes from the political realm into a structured judicial analysis, making it likely that future interbranch information conflicts of this nature will be resolved by courts applying this four-part framework.

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