Citation. 142 F.3d 496, 330 U.S. App. D.C. 48, 26 Med. L. Rptr. 1660 (D.C. Cir. 1998)
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Brief Fact Summary.
The Respondent, Paula Jones Corbin (Respondent), filed a complaint containing four counts against the Petitioner, President Clinton (Petitioner), alleging the Petitioner made unwanted sexual advances towards her when he was the Governor of Arkansas.
Synopsis of Rule of Law.
The United States Constitution (Constitution) does not automatically grant the President of the United States immunity from civil lawsuits based upon his private conduct unrelated to his official duties as President.
The Respondent filed a complaint against the Petitioner alleging that the Petitioner made unwanted sexual advances towards her when he was the Governor of Arkansas. The Petitioner filed motions asking the district court to dismiss the case on grounds of presidential immunity and to prohibit the Respondent from re-filing the suit until after the end of his presidency. The district court rejected the presidential immunity argument, but held that no trial would take place until the Petitioner was no longer president. Both parties appealed to the United States Supreme Court (Supreme Court), which granted certiorari.
Whether the President can be involved in a lawsuit during his presidency for actions that occurred before the tenure of his presidency and that were not related to official duties of the presidency?
The President of the United States can be involved in a lawsuit during his tenure for actions not related to his official duties as President.
It was an abuse of discretion of the District Court to order a stay of this lawsuit until after the President’s tenure. The District Court’s decision to order a stay was premature and a lengthy and categorical stay takes no account whatsoever of the Respondent’s interest in bringing the suit to trial.
Concurrence. It is important to recognize that civil lawsuits could significantly interfere with the public duties of an official. The concurring judge believed that ordinary case-management principles were likely to prove insufficient to deal with private civil lawsuits, unless supplemented with a constitutionally based requirement that district courts schedule proceedings so as to avoid significant interference with the President’s ongoing discharge of his official responsibilities.
A sitting President of The United States does not have immunity from civil lawsuits based on the President’s private actions unrelated to his public actions as President. The doctrine of separation of powers does not require federal courts to stay all private actions against the President until he leaves office. The doctrine of separation of powers is concerned with the allocation of official power among the three co-equal branches of government.