Nixon v. United States
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- This is about the 1993 case on the impeachment of Judge Walter Nixon. For the 1974 case on the powers of President Richard Nixon, see United States v. Nixon.
| Nixon v. United States | ||||||||||||||||
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| Argued October 14, 1992 Decided January 13, 1993 |
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| Holding | ||||||||||||||||
| The contention that Senate committees appointed to gather evidence in an impeachment trial are unconstitutional is nonjusticiable, because impeachment is a political question. | ||||||||||||||||
| Court membership | ||||||||||||||||
| Chief Justice: William Rehnquist Associate Justices: Byron White, Harry Blackmun, John Paul Stevens, Sandra Day O'Connor, Antonin Scalia, Anthony Kennedy, David Souter, Clarence Thomas |
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| Case opinions | ||||||||||||||||
| Majority by: Rehnquist Joined by: Stevens, O'Connor, Scalia, Kennedy, Thomas Concurrence by: Stevens Concurrence by: White Joined by: Blackmun Concurrence by: Souter |
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| Laws applied | ||||||||||||||||
| U.S. Const. Art. I | ||||||||||||||||
Nixon v. United States, 506 U.S. 224 (1993)[1], was a United States Supreme Court decision that determined that the question of whether the Senate had properly "tried" an impeachment was a political question, and could not be resolved in the Courts.
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[edit] Facts
In this case, a United States federal judge named Walter Nixon was going to be impeached by the United States House of Representatives for committing perjury before a grand jury. He was not impeached, but he resigned. The United States Senate appointed a committee to hear the evidence against Nixon, and then report to the body as a whole. Nixon contended that this did not meet the constitutional requirement of Article I that the case be "tried by the Senate."
[edit] Holding
The majority held that the courts may not review the impeachment and trial of a federal officer because the Constitution reserves that function to a coordinate political branch. Article I. Sec. 3 of the Constitution gave the Senate the "sole" power to "try" impeachments. Because of the word "sole" it is clear that the judicial branch was not to be included. Furthermore, because the word "try" was originally understood to include fact-finding committees, there was a textually demonstrable commitment to give broad discretion to the Senate in impeachments.
Furthermore the Framers believed that representatives of the people should try impeachments and the Court was too small to justly try impeachments. Also, the judicial branch is "checked" by impeachments, so that judicial involvement in impeachments might violate the doctrine of separation of powers. Note, the Senate is also "checked" because only the House can decide who to impeach.
The Court further ruled that involving the judiciary would prevent finality without clear remedy, and bias post-impeachment criminal or civil prosecutions which the Constitution explicitly allows.
Justices White, Blackmun and Souter concurred, but voiced concern that the Court was foreclosing this area for review. While they found that the Senate did all that was constitutionally required, they were concerned that the Court should have the power to review cases where the Senate removed an impeached officer summarily without a hearing, or through some arbitrary process, such as "a cointoss".
An important feature of this case is how it diverges from Powell v. McCormack. In Powell, a grant of discretionary power to Congress was deemed to be justiciable because it required a mere "interpretation" of the Constitution. Nixon v. U.S. illustrates the changing face of the political question doctrine as the Court retreated from the liberal standard of the Warren Court.
