Citation. 142 F.3d 496, 330 U.S. App. D.C. 48, 26 Med. L. Rptr. 1660 (D.C. Cir. 1998)
Law Students: Don’t know your Studybuddy Pro login? Register here
Brief Fact Summary.
Defendant allegedly sexually harassed Plaintiff. Plaintiff sued Defendant while he was the President of the United States. Defendant claimed official immunity from suit during the term of his presidency.
Synopsis of Rule of Law.
The President does not have temporary immunity from civil damage litigations arising out of acts committed prior to his presidency.
Jones (Plaintiff) alleged that President Clinton (Defendant) sexually harassed her. This conduct allegedly occurred in 1991. Afterwards, Defendant was elected President of the United States. Plaintiff’s complaint contains four counts, tow for violations of 42 U.S.C. Section:Section:1983 and 1985, and state law claims for intentional infliction of emotional distress and defamation. The alleged misconduct of Defendant was unrelated to any of his official duties as President of the United States and, indeed, occurred before he was elected to that office. Defendant filed a motion to dismiss the suit until the termination of his presidency. The district court denied Defendant’s motion. Defendant appealed.
Does the President have temporary immunity from civil damage litigations arising out of acts committed prior to his presidency?
No. Judgment for Plaintiff affirmed.
* Defendant’s principle submission – that in all but the most exceptional cases, the Constitution affords the President temporary immunity from civil damages litigation arising out of events that occurred before he took office – cannot be sustained on the basis of precedent. The principle rationale for affording certain public servants immunity form suits for money damages arising out of their official acts is inapplicable to unofficial conduct. The Court has never suggested that the President, or any other official, has an immunity that extends beyond the scope of any action taken in an official capacity.
* Defendant argues merely for a postponement of the judicial proceedings that will determine whether he violated any law. His argument is grounded in the character of the office that was created by Article II of the Constitution, and relies on separation-of-powers principles that have structured our constitutional arrangement since the founding.
* Defendant submits that – given the nature of the office – the doctrine of separation of powers places limits on the authority of the Federal Judiciary to interfere with the Executive Branch that would be transgressed by allowing this action to proceed. It does not follow, however, that separation-of-powers principles would be violated by allowing this action to proceed. Defendant contends that – as a byproduct of an otherwise traditional exercise of judicial power – burdens will be placed on the President that will hamper the performance of his official duties. It is settled law that the separation-of-powers doctrine does not bar every exercise of jurisdiction over the President of the United States. The burden of the President’s time and energy that is a mere byproduct of such review surely cannot be considered as onerous as the direct burden imposed by judicial review and the occasional invalidation of his official actions. The Court therefore held that the doctrine of separation
of powers does not require federal courts to stay all private actions against the President until he leaves office.
In this case, the Court held that this suit would not be a burden to Defendant as to infringe on the President’s duties articulated in Article II of the Constitution. In hindsight, clearly this suit was more than a burden. However, one could argue that it was not foreseeable Defendant would lie under oath.
Torts Keyed to Prosser, Wade & Schwartz (Tenth Edition)