Brief Fact Summary. Walter L. Nixon Jr. (Nixon) claimed that Senate impeachment hearings against him were unconstitutional because the entire Senate did not try him, but instead appointed a committee to make initial findings.
Synopsis of Rule of Law. A controversy is nonjusticiable if there is a textually demonstrable commitment of an issue to a coordinate branch of government or a lack of judicially manageable standards for resolving the controversy.
Facts. Nixon, a Chief Judge of the United States District Court, was the subject of an impeachment hearing before the Senate. The Senate appointed a committee under Senate Rule XI to create a report of findings regarding the impeachment of Nixon. Based on the findings of the committee and oral arguments from both the committee and Nixon, the Senate convicted Nixon by more than the constitutionally required two-thirds vote. Nixon commenced suit, claiming that Senate rule XI violates the constitutional grant of authority to the Senate to “try” all impeachments because it prohibits the entire Senate from taking part in the trial and evidentiary hearings. The District Court and the Court of Appeals held that the claim was nonjusticiable.
Issue. Is the constitutionality of Senate Rule XI nonjusticiable because it involves a political question?
Held. Yes. Judgment Affirmed.
A controversy is nonjusticiable because of the political question doctrine for one of two reasons. First, if a textually demonstrable constitutional commitment of the issue to a coordinate political department is present. Second, if a there is a lack of judicially discoverable and manageable standards for resolving the controversy. A lack of judicially manageable standards may strengthen a conclusion that there is a textually demonstrable commitment.
Nixon’s claim that the word “try” required proceedings in the nature of a judicial trial was rejected by the Court. The Court found that the word “try” has a broader meaning and that the Framers of the Constitution did not intend to impose additional limitations.
The Court found that the Constitution’s imposition of the sole power of impeachment on the Senate constituted a textually demonstrable commitment to a coordinate political department.
The Court also found that the Framers intentionally separated impeachment trials from criminal trials in order to avoid an appearance of bias and that a lack of finality and difficulty in fashioning relief counsels against adjudicating the matter.
Concurrence. Justice Stevens. The meaning of the words “sole” and “try” are not as significant as the designation of the impeachment power to the Legislative Branch.
Justices White and Blackmun. The matter is not a nonjusticiable political question. Nonetheless the Senate fulfilled its constitutional obligation to “try” Nixon.
Justice Souter. There are situations in which judicial review of an impeachment trial would be appropriate.
Discussion. The majority’s findings support the political question doctrine by declining to adjudicate matters textually committed in the Constitution to other branches of government.