## Facts

- Walter L. Nixon, Jr., a federal district judge, was convicted of making false statements to a grand jury and sentenced to prison.
- Nixon refused to resign and continued to receive his judicial salary while incarcerated.
- The House adopted three articles of impeachment and presented them to the Senate.
- Under Senate Impeachment Rule XI, the Senate appointed a committee to receive evidence and take testimony, then report to the full Senate.
- The committee conducted several days of hearings and submitted a report to the full Senate.
- The full Senate heard argument, questioned the parties, and voted by more than two-thirds to convict on two articles, removing Nixon from office.
- Nixon sued for declaratory and injunctive relief, arguing that the committee procedure meant the Senate had not “tried” the impeachment as required by Article I, § 3, cl. 6.

## Issues

1. Whether a federal court may review the Senate’s impeachment trial procedures to determine if an impeachment was “tried by the Senate” under Article I, § 3, cl. 6.
2. Whether Nixon’s challenge to the Senate’s use of an evidentiary committee under Rule XI presents a nonjusticiable political question.

## Decision

- The Supreme Court affirmed dismissal of the suit as nonjusticiable.
- The Impeachment Trial Clause’s grant that the Senate has the “sole Power to try all Impeachments” is a textual commitment of the issue to the Senate.
- The Constitution provides no judicially manageable standards for evaluating whether particular Senate procedures satisfy the requirement “to try.”
- Allowing judicial review of Senate impeachment trials would create serious separation-of-powers problems, particularly because impeachment is a congressional check on the judiciary.
- Several Justices concurred in the judgment, indicating that extreme departures from any plausible notion of a “trial” might present a different case, but concluding that the Rule XI procedure did not.

## Legal Principles

- Under the political question doctrine, courts will not decide disputes that the Constitution textually commits to a coordinate political branch or that lack judicially manageable standards.
- The Senate’s “sole Power to try all Impeachments” commits impeachment trial procedure to the Senate, subject to the Constitution’s express requirements (including the oath/affirmation requirement, the two-thirds vote to convict, and the Chief Justice presiding when the President is tried).
- The term “try” in the Impeachment Trial Clause is too indeterminate to supply enforceable judicial standards for supervising Senate methods, including the use of committees to gather evidence.
- Judicial review of impeachment trial procedure threatens finality and risks institutional conflict inconsistent with separation of powers.

## Conclusion

The Court held that a judge removed after a Senate impeachment conviction cannot obtain judicial review of the Senate’s chosen procedures, including use of a committee to take evidence, because challenges to whether the Senate has properly “tried” an impeachment are political questions committed to the Senate by the Constitution.


Nixon v. United States, 506 U.S. 224 (1993)