Law School Case Brief
Nixon v. United States - 506 U.S. 224, 113 S. Ct. 732 (1993)
A controversy is nonjusticiable -- i. e., involves a political question -- where there is a textually demonstrable constitutional commitment of the issue to another political department; or a lack of judicially discoverable and manageable standards for resolving it. The concept of a textual commitment to a another political department is not completely separate from the concept of a lack of judicially discoverable and manageable standards for resolving it; the lack of judicially manageable standards may strengthen the conclusion that there is a textually demonstrable commitment to another branch.
After petitioner Nixon, the Chief Judge of a Federal District Court, was convicted of federal crimes and sentenced to prison, the House of Representatives adopted articles of impeachment against him and presented them to the Senate. Following proceedings pursuant to Senate Rule XI -- which allows a committee of Senators to hear evidence against an impeached individual and to report that evidence to the full Senate -- the Senate voted to convict Nixon, and the presiding officer entered judgment removing him from his judgeship. He then commenced the present suit for a declaratory judgment and reinstatement of his judicial salary and privileges, arguing that, because Senate Rule XI prohibited the whole Senate from taking part in the evidentiary hearings, it violated the first sentence of the Constitution's Impeachment Trial Clause, Art. I, § 3, cl. 6, which provides that the "Senate shall have the sole Power to try all Impeachments." The District Court held that his claim was nonjusticiable as it involved a political question that could not be resolved by the courts.
Is there a justiciable controversy?
The Court held the controversy was a nonjusticiable political question as there was a textually demonstrable constitutional commitment of the issue to the legislature and a lack of judicially discoverable and manageable standards for resolving it. The Impeachment Clause granted sole authority over impeachments to the Senate, and did not require or provide a means of judicial review. As impeachment was designed to be the only check on the judiciary by the legislature, it was counterintuitive to have judicial review of impeachment proceedings. There were no discoverable standards for judicial review of impeachment proceedings, and fashioning relief was difficult.
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