Nixon v. United States

Supreme Court of the United States · 1993 · Constitutional Law

506 U.S. 224 (1993)

Updated July 29, 2026

Constitutional LawImpeachmentPolitical Question DoctrineJusticiabilitySeparation of PowersImpeachment Trial ClauseSenate Rule XIsole Power to try all Impeachments

Facts

Walter L. Nixon, Jr., a federal district judge, was convicted of making false statements before a federal grand jury and refused to resign, continuing to receive his judicial salary. The House adopted three articles of impeachment, and the Senate invoked Rule XI, under which a committee of Senators received evidence and testimony and reported a transcript and summary to the full Senate. Nixon and the House managers then submitted briefs and presented arguments to the full Senate, and the Senate convicted Nixon on two articles by more than a two-thirds vote and removed him from office. Nixon claimed Rule XI violated Article I, Section 3, Clause 6 because the full Senate did not itself hear the evidence.

Issue

Whether a claim that the Senate's use of Rule XI violated the Impeachment Trial Clause's command that the Senate have the sole Power to try all Impeachments is justiciable in federal court. More specifically, the question was whether courts may review the Senate's procedures for conducting an impeachment trial.

Rule

Challenges to the Senate's procedures for trying impeachments present a nonjusticiable political question when the Constitution textually commits the sole power to try impeachments to the Senate and the term at issue provides no judicially discoverable and manageable standard for review. The word "try" in the Impeachment Trial Clause does not create an identifiable textual limit enforceable by the judiciary beyond the Clause's express requirements.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

The House impeaches a federal district judge from Ohio. During the Senate proceedings, a panel of senators hears live testimony in Cleveland, sends a transcript and summary to the full Senate in Washington, and the full Senate later votes to convict by more than two-thirds after briefing and floor argument.

If the removed judge sues in federal court arguing that the Constitution required the entire Senate to hear the witnesses personally, how should the court rule?

Explanation. The claim is nonjusticiable under the majority's reasoning. The Impeachment Trial Clause gives the Senate the "sole Power to try all Impeachments," which is a textually demonstrable commitment to the Senate. The challenge depends on reading additional procedural limits into the word "try," but the Court held that term lacks sufficient precision to supply judicially discoverable and manageable standards for reviewing Senate procedures.