Clinton v. Jones

Citation. 520 U.S. 681, 117 S.Ct. 1636, 137 L.Ed.2d 845 (1997)

Brief Fact Summary.

Paula Jones sued President Clinton for making unwanted sexual advances while he was the Governor of Arkansas.  President Clinton argued that the Constitution requires any litigation be deferred until his Presidency ended.

Synopsis of Rule of Law.

While the President is “entitled to absolute immunity from damages liability predicated on his official acts,” Nixon v. Fitzgerald, 457 U.S. 731 (1982), the President is not immune from suit for his unofficial conduct.

Facts.

Paula Jones staffed the registration desk at an Arkansas hotel where then Governor Clinton was delivering a speech.  She alleged that Clinton invited her to his room where he made unwanted sexual advances.  She brought a civil rights suit, alleging that Governor Clinton, acting under color of state law, deprived her of her constitutional rights.  The alleged misconduct occurred prior to Clinton’s Presidency, but the lawsuit occurred during his Presidency.

Issue.

Whether a private citizen may bring a civil suit against the President in federal court for conduct that occurred prior to his Presidency.

Held.

JUSTICE STEVENS holding:  Yes.  The President is not immune from being sued for acts that extend beyond the scope of his official capacity.

Discussion.

The Court reasoned that there was nothing in American history or the Court’s precedent to support the argument that the President was immune from being sued for his unofficial conduct.  For example, President John F. Kennedy was sued for civil damages arising from a car accident, and his motion to stay was similarly denied by a district court, leading to the matter being settled out of court.

President Clinton argued that separation of powers concerns demanded that the litigation be stayed.  In effect, his argument was that the public interest demands that he devote his undivided attention to his Presidential duties, and enabling the suit to go forward would be to allow the Judiciary to interfere with the Executive Branch.  The Court rejected this argument, reasoning that there was “no perceptible risk of misallocation of either judicial power or executive power.”  In deciding the case, a federal court would merely be exercising its core function under Article III to “decide cases and controversies.”  Even if the President were to lose the case, the holding would not limit the powers of the Executive Branch.  President Clinton further argued that, if the Court allowed the case to go forward, there would be a wave of politically-motivated litigation that would burden the President and impair his ability to serve the people.  The Court found this argument unlikely, reasoning that in more than 200 years only three sitting Presidents had ever been sued for private actions.  Further, frivolous litigation is often terminated during the pleading stage, and sanctions for frivolous suits provide a significant deterrent.

The Court tempered its opinion by urging lower courts, in deciding whether to stay cases such as these, to consider the respect owed to the President and his duties while deciding the “timing and scope of discovery.”  Accordingly, lower courts can stay proceedings based upon the magnitude of the President’s duties without recognizing any form of immunity.  However, the categorical stay order by the District Court did not consider Jones’ interest in bringing the case and there was no evidence that a stay was required.  Therefore, the Court affirmed the Court of Appeals and rejected the stay order.