Clinton v. Jones

Brief Fact Summary.

Corbin Jones filed a civil lawsuit against President Clinton while he held office. The lawsuit was based on acts that occured before he was elected, and were unrelated to his official duties as president.

Synopsis of Rule of Law.

The doctrine of separation of powers does not require the President to be immune from civil actions arising out of his unofficial acts.

Facts.

Corbin Jones filed a complaint in which she alleged that President Clinton, who held presidential office when this case was decided, sexually harrassed or sexually assaulted her before he was elected to office. The actions the President was accused of were unrelated to his official duties as president.

Issue.

Does the separation of powers doctrine barr all civil lawsuits against the President until he leaves office?

Held.

No, the separation of powers doctrine doctrine does not barr all civil lawsuits against the President until he leaves office.

Concurrence.

Justice Breyer

Justice Breyer agreed with the Supreme Court’s holding that there is no authomatic Presidential immunity from civil actions arising out of his unofficial conduct, but argued that district courts must schedule proceedings to avoid significant interference with the President’s discharge of his duties.

Discussion.

The Supreme Court began by noting that certain public officials have immunity from actions arising out of their official acts. See Nixon v. Fitzgerald. However, the Supreme Court noted that the rational for this immunity is that it allows officials to perform their functions effectively without the fear that they may be held personally liable in court. According to the Supreme Court, this rationale does not extend to unofficial acts of public officials, and there is no precedent to construct an immunity for unofficial acts.

The Supreme Court rejected President Clinton’s argument that the separation of powers doctrine allows for such an immunity. President Clinton argued that, without this immunity, the office of the president would be subject to so many lawsuits that it would would constitute a constitutionally forbidden impairment of the executive branch’s ability to perform its duties under Article II. The Supreme Court held that federal courts’ exercise of their Article III jurisdiction, even if burdensome to the President, do not rise to the level of a Constitutional violation. The Supreme Court cited two established principles to support this conclusion. First, that the Court has the authority to determine whether the President has acted within the law when he takes official action. Second, that the President is subject to judicial process in certain circumstances.

The Supreme Court held that it was an abuse of discretion for the District Court to stay the trial until after the President left office, because delaying the trial would increase the risk of prejudice resulting from the loss of evidence.