Nixon v. United States
Citation and Court
506 U.S. 224 (1993) — Supreme Court of the United States
Facts
Walter Nixon, a federal district judge, was convicted of making false statements to a federal grand jury and was imprisoned. The Senate conducted his impeachment trial by first referring the evidence to a Senate committee, which heard testimony, and then presenting the full Senate with a report. The full Senate voted to convict and remove Nixon from office. Nixon argued that the Senate’s use of a committee to gather evidence — rather than having the full Senate hear all evidence — violated the Impeachment Trial Clause.
Issue
Whether the Senate’s use of a committee to gather evidence in an impeachment trial is a nonjusticiable political question or subject to judicial review.
Holding
The Senate’s power to “try” impeachments under Article I is a nonjusticiable political question; federal courts lack jurisdiction to review whether the Senate conducted an impeachment trial in accordance with its constitutional obligations.
Rule / Doctrine
Political question doctrine applied to impeachment: the Impeachment Trial Clause gives the Senate the “sole power to try” impeachments, and this textual commitment of the issue to the Senate, combined with a lack of judicially manageable standards for evaluating what constitutes a proper “trial,” makes judicial review of Senate impeachment procedures unavailable.
Significance
Nixon v. United States is the leading modern case on the political question doctrine as applied to impeachment and establishes that the Senate’s procedural choices in conducting impeachment trials are entirely beyond judicial supervision. Combined with Baker v. Carr (1962), it defines the political question doctrine’s outer limits.