Trump v. Mazars USA, LLP - 140 S. Ct. 2019 (2020)

Rule:

Disputes regarding congressional demands for presidential documents can raise important issues concerning relations between the branches; related disputes involving congressional efforts to seek official Executive Branch information recur on a regular basis, including in the context of deeply partisan controversy; and Congress and the Executive have nonetheless managed for over two centuries to resolve such disputes among themselves without the benefit of guidance from the Court. Such long-standing practice is a consideration of great weight in cases concerning the allocation of power between the two elected branches of government, and it imposes on a duty of care to ensure that the court not needlessly disturb the compromises and working arrangements that those branches themselves have reached.

Facts:

In April 2019, three committees of the U. S. House of Representatives issued four subpoenas seeking information about the finances of President Donald J. Trump, his children, and affiliated businesses. Although each of the committees sought overlapping sets of financial documents, each supplied different justifications for the requests, explaining that the information would help guide legislative reform in areas ranging from money laundering and terrorism to foreign involvement in U. S. elections. Petitioners—the President in his personal capacity, along with his children and affiliated businesses—contested the subpoena issued by the Oversight Committee in the District Court for the District of Columbia and the subpoenas issued by the Financial Services and Intelligence Committees in the Southern District of New York. In both cases, petitioners contended that the subpoenas lacked a legitimate legislative purpose and violated the separation of powers. The respective district courts held that the subpoenas served a valid legislative purpose because the requested information was relevant to reforming financial disclosure requirements for Presidents and presidential candidates. 

Issue:

Was it proper to countenance the issuance of subpoenas which sought information about the finances of the President?

Answer:

No.

Conclusion:

The Court held that executive privilege was not to be transplanted root and branch to cases involving nonprivileged, private information, which by definition did not implicate sensitive Executive Branch deliberations. –When Congress sought information needed for intelligent legislative action, it unquestionably remained the duty of all citizens to cooperate. Congressional subpoenas for information from the President, however, implicated special concerns regarding the separation of powers. The courts below did not take adequate account of those concerns. Accordingly, the judgments were vacated, and the cases were remanded.