Law School Case Brief
Trump v. Mazars United States - 940 F.3d 710 (D.C. Cir. 2019)
The Ethics in Government Act of 1978 requires many aspiring and current government officials, including presidential candidates and sitting Presidents, to file financial disclosure reports at various times during their candidacies and incumbencies. 5 U.S.C.S. app. 4, § 101(a), (c), (d), (f) requires a candidate for nomination or election to the office of President and the President to file a report containing the information described in § 102 of the Act. In their initial reports, presidential candidates and new Presidents must provide information concerning their income, assets, liabilities, and employers. Section 102(b) requires each report filed pursuant to § 101(a), (b), and (c) to contain such information. Once in office, sitting Presidents must file annual reports disclosing that same information plus details about any covered gifts, real estate and securities transactions, and blind trusts. Section 102(a) requires each report filed pursuant to § 101(d) and (e) to contain such information. Presidential candidates submit their reports to the Federal Election Commission, 5 U.S.C.S. app. 4, § 103(e), while incumbent Presidents file with the Office of Government Ethics, an executive agency tasked with interpreting rules and regulations governing the filing of financial statements, 5 U.S.C.S. app. 4, §§ 103(b), 401(a), 402(b)(3), 402(b)(6).
On April 15, 2019, the House Committee on Oversight and Reform issued a subpoena to the accounting firm Mazars USA, LLP for records related to work performed for President Trump and several of his business entities both before and after he took office. According to the Committee, the documents will inform its investigation into whether Congress should amend or supplement current ethics-in-government laws. For his part, the President contends that the Committee's investigation into his financial records serves no legitimate legislative purpose, and he has sued to prevent Mazars from complying with the subpoena. The district court granted summary judgment in favor of the Committee.
Was the President’s contention that Committee's investigation into his financial records serves no legitimate legislative purpose meritorious?
The Court held that an accounting firm had to comply with the House Committee on Oversight and Reform's subpoena for records related to work performed for the President of the United States and several of his business entities both before and after he took office because the Committee possessed authority under both the House Rules and the Constitution to issue the subpoena as the public record revealed legitimate legislative pursuits, not an impermissible law-enforcement purpose, behind the subpoena; given the constitutionally permissible options open to Congress in the field of financial disclosure, the subpoena sought information about a subject on which legislation could be had; the documents requested in the subpoena were relevant to the Committee's investigation; and under the most natural reading of the House Rules, the full chamber authorized the Committee to issue the subpoena.
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