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Supreme Court of the United States - 506 U.S. 224
Tags: Constitutional Law, Political Question
See also: Baker v. Carr
The case involves Walter L. Nixon Jr., a former Chief Judge of the United States District Court for the Southern District of Mississippi, who was convicted of making false statements before a federal grand jury and sentenced to prison. Nixon argues that Senate Rule XI, which allows a committee of Senators to hear evidence against an individual who has been impeached and to report that evidence to the full Senate, violates the Impeachment Trial Clause. The Supreme Court concludes that the Senate has the sole power to try all impeachments, and the word "sole" indicates that this authority is reposed in the Senate and nowhere else. The Constitution's use of the word "try" in the Impeachment Trial Clause does not limit the method by which the Senate may proceed in trying impeachments. Judicial review of the Senate's trial would introduce the same risk of bias as would participation in the trial itself.
Justice Stevens agrees with the decision to give the power of impeachment to the Legislative Branch, citing the Senate's handling of Samuel Chase's impeachment in 1805. He believes that respecting the authority of another branch of government means not assuming unlikely hypothetical scenarios. He supports judicial restraint and avoiding potential anomalies that could arise from a different view, aligning with The Chief Justice's perspective.
The legal case involves a petitioner who argues that the Senate's method of convicting him on two articles of impeachment violates the Constitution. The Court finds that it cannot review this argument, but Justice White disagrees. The majority found a clear textual commitment in the Constitution's use of the word "sole" in the Impeachment Trial Clause, indicating that the Senate has exclusive interpretive authority over the Clause. The author disagrees with the majority's interpretation of the term "sole," arguing that it emphasizes the distinct role of each House in the impeachment process and effectuates the separation of prosecutorial and adjudicative aspects of impeachment. Ultimately, Justice White agrees with the judgment because the Senate fulfilled its constitutional duty by "trying" the petitioner. The passage argues that the Court's refusal to review the constitutionality of legislative acts related to impeachment based solely on the word "sole" in the Impeachment Trial Clause is confusing and upsets the Framers' careful design of a balanced system where impeachments tried by the Senate would control the largely unaccountable Judiciary, and judicial review would ensure that the Senate adhered to a minimal set of procedural standards in conducting impeachment trials.
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