- [Narrator] The last time federal judge Walter Nixon
stood inside a courtroom,
it was not to preside over a trial,
but to stand trial himself.
Nixon was accused of attempting to sway authorities
to drop marijuana smuggling charges
against the son of Nixon's longtime friend.
In exchange for getting the charges dropped,
Nixon was allegedly promised oil and gas royalties
from his friend's business.
Nixon was convicted of perjury for lying to the grand jury.
Declaring his innocence from behind bars,
Nixon refused to give up his judicial commission.
As a result, the House of Representatives was forced
to begin impeachment proceedings against him.
The impeachment power in the Constitution
is divided between the House and the Senate.
The House acts as the prosecutor,
and the Senate acts as the jury.
In Nixon's case, the House presented
three articles of impeachment to the Senate.
The Senate then heard evidence against Nixon
and convicted him.
Nixon was unhappy with how his impeachment trial went.
In an ordinary trial, the jury hears
all of the evidence firsthand.
But the senators, pressed for time,
instead appointed a committee to hear the evidence.
That committee then presented the full Senate
with a complete transcript of the hearing,
along with a report summarizing the evidence.
Based on that report, the full Senate voted to convict.
After his impeachment, Nixon sued the United States,
arguing that the Senate violated Article I,
Section III, Clause VI of the Constitution,
also known as the Impeachment Trial Clause.
Nixon objected to the Senate's appointment of a committee
to conduct the evidentiary hearing, arguing that
the Impeachment Trial Clause required the entire Senate
to hear the evidence firsthand.
The District Court held that Nixon's claim
presented a non-justiciable political question,
and dismissed the case.
The Court of Appeals agreed.
The question for the United States Supreme Court was whether
reviewing the Senate's impeachment proceedings
presented a non-justiciable political question.
The Court held that review of impeachment proceedings
is a non-justiciable political question.
This is because the impeachment power is constitutionally
reserved to the political branches of government.
Additionally, the Court found no judicially manageable
standards for resolving the dispute.
Chief Justice Rehnquist, writing for the Court,
determined that the word "sole"
in the Impeachment Trial Clause
gives the Senate complete discretion
to conduct impeachment proceedings.
This includes the authority to make the rules
that govern impeachment procedure.
The court also determined that the word try
in the impeachment trial clause is not precise enough
for judicial application.
The word is not defined in the Constitution,
and contemporary dictionaries indicate that it could mean
anything from a judicial trial to a simple investigation.
As a result, the Court concluded that there were
no judicially manageable standards for determining
how the Senate must conduct an impeachment.
The Court affirmed the court of appeals,
and ordered Nixon's claim to be dismissed.
Justice Stevens wrote a concurring opinion,
arguing that the Framers deliberately gave
complete impeachment power to the legislative branch.
Therefore, any interference from the judiciary
would be inappropriate.
Justice White concurred in judgment,
but disagreed with the majority that the case
presented a non-justiciable question.
White argued that the word "sole"
in the Impeachment Trial Clause doesn't mean that
the Senate is the exclusive authority on impeachment.
Rather, White resented that the Framers used the term
to emphasize the distinct authority of the House
to prosecute impeachments, and the distinct authority
of the Senate to try impeachments.
In addition, White argued that
the word "try" isn't ambiguous.
Judges, who are experts at trying cases, are well-situated
to come up with standards to determine
whether Nixon had been properly tried.
Although White disagreed with the majority on
the political question issue, he agreed with
the ultimate outcome, because Nixon's impeachment trial
was constitutionally proper.
Justice Souter also concurred in judgment.
Souter argued that the judiciary should be allowed to review
the Senate's impeachment determination in extreme cases.
Souter thought judicial oversight would be needed
if the Senate grossly abused its discretion.
For example, the Senate might try
deciding the outcome with a coin toss.
In that situation, the judiciary would need to intervene.
Nixon versus United States further developed
the political question doctrine by emphasizing
the importance of textual analysis.