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Nixon v. US

506 U.S. 224 (1993)

tl;dr: [Abrv.] The method of impeachment proceedings is a nonjusticiable political questions.

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The case of Nixon v. United States et al. involved a former Chief Judge, Walter L. Nixon Jr., who was convicted of making false statements before a grand jury and sentenced to prison. Despite his conviction, Nixon refused to resign from his position as a United States District Judge and continued to collect his salary while serving his sentence. The House of Representatives impeached Nixon on three articles, and the Senate invoked its own Impeachment Rule XI and appointed a committee to receive evidence and take testimony. The Senate voted by more than the required two-thirds majority to convict Nixon on the first two articles, and he was removed from his office as United States District Judge. Nixon sued, claiming that Senate Rule XI violated the Constitution by preventing the whole Senate from participating in impeachment hearings. The District Court and the Court of Appeals for the District of Columbia Circuit ruled that his claim was not justiciable. The Supreme Court granted certiorari to determine if the claim is justiciable by examining Article I, Section 3, Clause 6 to determine the scope of the Senate's authority regarding impeachment. The language and structure of Article I, Section 3, Clause 6 reveal that the Senate has the sole power to try all impeachments, and the requirements for Senate proceedings are specified in the next two sentences. The petitioner argues that the word "try" implies that the proceedings must be in the nature of a judicial trial, which precludes the Senate from delegating the task of hearing testimony to a select committee. The petitioner concludes that courts may review whether the Senate "tried" the defendant before convicting them. However, the lower courts ruled that Nixon's claim was not justiciable due to the political nature of impeachment proceedings.

The Senate has the sole power to try impeachments, and the word "try" does not limit the Senate's methods for trying impeachments. The Judiciary was intentionally excluded from having a role in impeachments to ensure independent judgments. The Senate has final authority to determine the meaning of "try" in the Impeachment Trial Clause, and the word "sole" means that there is no judicial review of the Senate's actions in an impeachment trial. The case involves a political question, and the majority believes that the Senate has exclusive interpretive authority over the Impeachment Trial Clause. The dissenting opinion questions the Court's decision to not review the constitutionality of legislative acts based solely on the word "sole" in the Impeachment Trial Clause. The Court's finding of nonjusticiability upsets the Framers' careful design for a balanced system.

The majority's argument that the term "try" in the Impeachment Trial Clause cannot be reviewed is flawed. The use of a fact-finding committee is compatible with the Constitution's command to "try all impeachments." The petitioner's challenge to their conviction fails as it is a nonjusticiable political question. The Senate has exclusive power to try impeachments, but judicial interference may be appropriate in certain circumstances. The political question doctrine should not be applied in a way that promotes disorder.

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IRACIssue, Rule, Analysis, Conclusion

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Facts & Holding

Facts:Article I sets forth specific procedures for Congress to conduct...

Holding: Impeachment proceedings are non-justiciable political questionsTextual limit: “sole power to...

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Nixon v. US

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