Nixon v. United States

Background

Walter L. Nixon Jr., a former federal district judge, was convicted in criminal court of making false statements. The House adopted three articles of impeachment and the Senate, invoking Rule XI, appointed a committee to take testimony and prepare a transcript and report for the full Senate. The full Senate received briefs and oral argument, convicted Nixon on two articles, and removed him. Nixon then sued to void the conviction and regain his salary and office.

Reasoning

The Court first asked whether Nixon’s claim could be decided by judges and concluded it could not. Applying the political-question doctrine, the majority said the Constitution gives the Senate the “sole” power to try impeachments and that the word “try” does not provide a clear, judicially manageable standard. The opinion pointed to the Clause’s three explicit requirements (oath, Chief Justice for presidential trials, two-thirds to convict), historical materials, separation-of-powers concerns, finality problems, and difficulties in fashioning relief, and thus affirmed dismissal.

Real world impact

The decision means federal courts generally will not review how the Senate organizes or conducts impeachment factfinding, including use of committees under Rule XI. Removed officials will have limited judicial recourse to challenge Senate procedures. Because the Court treated the question as nonjusticiable, it did not reach the merit question whether Rule XI itself violates the Constitution.

Dissents or concurrances

Several Justices agreed in result but differed on reasoning. Justice White would have reached the merits and concluded the Senate’s process satisfied the Constitution. Justice Souter concurred that the case was nonjusticiable but emphasized prudential limits. Justice Stevens stressed deference to the Legislature’s role.