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Nixon v. United States

Brief Fact Summary. Walter Nixon (P) was a federal judge who was impeached by the House and convicted by the Senate on bribery charges. He challenged his impeachment based on the procedures used by the Senate.

Synopsis of Rule of Law. The Senate Impeachment Clause in the Constitution makes clear that “the Senate shall have sole power to try all Impeachments”. Thus, this is a political question and not reviewable by the Court.

Facts. Plaintiff was charged with bribery and convicted by the Senate. The House later impeached him. P argued that the Senate had used a committee of Senators to hold hearings on the bribery accusations. This committee reported their findings to the full Senate and they voted by majority to convict him. P claimed that the Constitution requires the Senate to try all impeachments and therefore because only a Committee reviewed the evidence instead of the entire Senate, the Senate had not followed proper procedure.

Issue. Is this a justiciable issue that the Supreme Court can review?

Held. No. This is not a justiciable issue, but instead is a political question. The Senate had the sole power to determine what kind of trial procedure they use to review evidence in impeachment cases as granted to them via the Constitution.
Concurrence. The question was not whether the Constitution gave exclusive power to a branch of government, but whether responsibility rested with that branch. Thus, there could be situations in the future where impeachment proceedings are reviewable by the Court.

Discussion. If the Constitution clearly states that an issue is committed to another branch of government, then the Supreme Court will treat it as a non-justiciable political question.