Impeachment in the United States

From Wikipedia, the free encyclopedia
Jump to navigation Jump to search

 This article incorporates public domain material from websites or documents of the United States Government.

Impeachment in the United States is the process by which the lower house of a legislature brings charges against a civil officer of government for crimes alleged to have been committed, analogous to the bringing of an indictment by a grand jury. At the federal level, this is at the discretion of the House of Representatives. Most impeachments have concerned alleged crimes committed while in office, though there have been a few cases in which officials have been impeached and subsequently convicted for crimes committed prior to taking office;[1] the impeached official remains in office until a trial is held. That trial, and their removal from office if convicted, is separate from the act of impeachment itself. Analogous to a trial before a judge and jury, these proceedings are (where the legislature is bicameral) conducted by upper house of the legislature, which at the federal level is the Senate.

Impeachment may occur at the federal level or the state level; the federal House can impeach federal officials, and each state's legislature can impeach state officials, including the governor, in accordance with their respective federal or state constitution.

Federal impeachment[edit]

Constitutional provisions[edit]

The House of Representatives ... shall have the sole Power of Impeachment.

Article I, Section 2, Clause 5

The Senate shall have the sole Power to try all Impeachments; when sitting for that Purpose, they shall be on Oath or Affirmation. When the President of the United States is tried, the Chief Justice shall preside: And no Person shall be convicted without the Concurrence of two thirds of the Members present. Judgment in Cases of Impeachment shall not extend further than to removal from Office, and disqualification to hold and enjoy any Office of honor, Trust or Profit under the United States; but the Party convicted shall nevertheless be liable and subject to Indictment, Trial, Judgment and Punishment, according to Law.

Article I, Section 3, Clauses 6 and 7

[The President} … shall have power to grant reprieves and pardons for offenses against the United States, except in cases of impeachment.

Article II, Section 2

The President, Vice President and all civil Officers of the United States, shall be removed from Office on Impeachment for, and Conviction of, Treason, Bribery, or other high Crimes and Misdemeanors.

Article II, Section 4

See also

Impeachable offenses: "High Crimes and Misdemeanors" [edit]

see also High Crimes and Misdemeanors

The Constitution limits grounds of impeachment to "treason, bribery, or other high crimes and misdemeanors";[3] the precise meaning of the phrase "high crimes and misdemeanors" is not defined in the Constitution itself.

The notion that only criminal conduct can constitute sufficient grounds for impeachment does not comport with either the views of the founders or with historical practice.[1] Alexander Hamilton, in Federalist 65, described impeachable offenses as arising from “the misconduct of public men, or in other words from the abuse or violation of some public trust.”[4] Such offenses were “political, as they relate chiefly to injuries done immediately to the society itself.”[4] According to this reasoning, impeachable conduct could include behavior that violates an official’s duty to the country, even if such conduct is not necessarily a prosecutable offense. Indeed, in the past both houses of Congress have given the phrase “high Crimes and Misdemeanors” a broad reading, “finding that impeachable offenses need not be limited to criminal conduct.”[5][1]

The purposes underlying the impeachment process also indicate that non-criminal activity may constitute sufficient grounds for impeachment;[1] the purpose of impeachment is not to inflict personal punishment for criminal activity. Instead, impeachment is a “remedial” tool; it serves to effectively “maintain constitutional government” by removing individuals unfit for office.[6][1] Grounds for impeachment include abuse of the particular powers of government office or a violation of the “public trust”—conduct that is unlikely to be barred via statute.[6][5][1]

In drawing up articles of impeachment, the House has placed little emphasis on criminal conduct.[1] Less than one third of the articles that the House have adopted have explicitly charged the violation of a criminal statute or used the word “criminal” or “crime” to describe the conduct alleged.[1] Officials have been impeached and removed for drunkenness, biased decisionmaking, or inducing parties to enter financial transactions, none of which is specifically criminal.[1] Two of the articles against Andrew Johnson were based on rude speech that reflected badly on the office: President Johnson had had made “harangues” criticizing the Congress and questioning its legislative authority, refusing to follow laws, and diverting funds allocated in an army appropriations act, each of which brought the presidency “into contempt, ridicule, and disgrace.”[7] A number of individuals have been impeached for behavior incompatible with the nature of the office they hold;[1] some impeachments have addressed, at least in part, conduct before the individuals assumed their positions: for example, Article IV against Judge Porteous related to false statements to the FBI and Senate in connection with his nomination and confirmation to the court.[1]

On the other hand, the Constitutional Convention rejected language that would have permitted impeachment for "maladministration," with Madison arguing that "[s]o vague a term will be equivalent to a tenure during pleasure of the Senate." [8]

Congressional materials have cautioned that the grounds for impeachment “do not all fit neatly and logically into categories” because the remedy of impeachment is intended to “reach a broad variety of conduct by officers that is both serious and incompatible with the duties of the office.”[6][1] Congress has identified three general types of conduct that constitute grounds for impeachment, although these categories should not be understood as exhaustive:

(1) improperly exceeding or abusing the powers of the office;
(2) behavior incompatible with the function and purpose of the office; and
(3) misusing the office for an improper purpose or for personal gain.[6][1]

Conversely, not all criminal conduct is impeachable: in 1974, the Judiciary Committee rejected an article of impeachment against President Nixon alleging that he committed tax fraud, primarily because that “related to the President’s private conduct, not to an abuse of his authority as President.”[1]

Several commentators have suggested that Congress alone may decide for itself what constitutes a "high crime or misdemeanor", especially since the Supreme Court decided in Nixon v. United States that it did not have the authority to determine whether the Senate properly "tried" a defendant.[9] In 1970, then-House Minority Leader Gerald R. Ford defined the criterion as he saw it: "An impeachable offense is whatever a majority of the House of Representatives considers it to be at a given moment in history."[10]

Of the 17 impeachments voted by the House:

  • no official has been charged with treason. (In 1797, Senator Blount was impeached for assisting Britain in capturing Spanish territory. In 1862, Judge Humphries was impeached and convicted for siding with the Confederacy and taking a position as a Confederate judge during the Civil War.)
  • Three officials have been charged with bribery, and all three removed (Secretary Belknap, Judge Archibald, and Judge Hastings).
  • The remaining charges against all the other officials fall under the category of “high crimes and misdemeanors.”

The standard of proof required for impeachment and conviction is also left to the discretion of individual Representatives and Senators, respectively. Defendants have argued that impeachment trials are in the nature of criminal proceedings, with convictions carrying grave consequences for the accused, and that therefore proof beyond a reasonable doubt should be the applicable standard. House Managers have argued that a lower standard would be appropriate to better serve the purpose of defending the community against abuse of power, since the defendant does not risk forfeiture of life, liberty, or property.[11]

Officers subject to impeachment: "civil officers of the United States" [edit]

The Constitution gives Congress the authority to impeach and remove the "The President, Vice President, and all civil officers of the United States" upon a determination that such officers have engaged in treason, bribery, or other high crimes and misdemeanors; the Constitution does not articulate who qualifies as a “civil officer of the United States.”[12]

Federal judges are subject to impeachment. In fact, 15 of 19 officers impeached, and all eight officers removed after Senate trial, have been judges.

Within the executive branch, any Presidentially-appointed "principal officer," including a head of an agency such as a Secretary, Administrator, or Commissioner, is a "civil officer of the United States" subject to impeachment.[1] At the opposite end of the spectrum, lesser functionaries, such as federal civil service employees, do not exercise “significant authority,” and are not appointed by the President or an agency head; these employees do not appear to be subject to impeachment, though that may be a matter of allocation of House floor debate time by the Speaker, rather than a matter of law.

The Senate has concluded that members of Congress (Representatives and Senators) are not "civil officers" for purposes of impeachment;[13] as a practical matter, expulsion is effected by the simpler procedures of Article I, Section 5, which provides "Each House shall be the Judge of the Elections, Returns and Qualifications of its own Members... Each House may determine the Rules of its Proceedings, punish its Members for disorderly Behaviour, and, with the Concurrence of two thirds, expel a Member." (see List of United States senators expelled or censured and List of United States Representatives expelled, censured, or reprimanded). This allows each House to expel its own members without involving the other chamber. In 1797, the House of Representatives impeached Senator William Blount of Tennessee,[14] The Senate expelled Sen. Blount under Art. I sec. 5 on the same day. However, the impeachment proceeding remained pending (expulsion only removes the individual from office, but removal after impeachment bars the individual from holding future office, so the question of further punishment remained to be decided). After four days of debate, the Senate concluded that a Senator is not a "civil officer of the United States" for purposes of the Impeachment clause, and dismissed for lack of jurisdiction;[13][15] the House has not impeached a Member of Congress since Blount.

Procedure[edit]

At the federal level, the impeachment process is a three-step procedure.

  • First, the Congress investigates. This investigation typically begins in the House Judiciary Committee, but may begin elsewhere. For example, the Nixon impeachment inquiry began in the Senate Judiciary Committee; the facts that led to impeachment of Bill Clinton were first discovered in the course of an investigation by Independent Counsel Kenneth Starr.
  • Second, the House of Representatives must pass, by a simple majority of those present and voting, articles of impeachment, which constitute the formal allegation or allegations. Upon passage, the defendant has been "impeached".
  • Third, the Senate tries the accused. In the case of the impeachment of a president, the Chief Justice of the United States presides over the proceedings. For the impeachment of any other official, the Constitution is silent on who shall preside, suggesting that this role falls to the Senate's usual presiding officer, the President of the Senate who is also the Vice President of the United States. Conviction in the Senate requires a two-thirds vote; the result of conviction is removal from office.

Rules[edit]

A number of rules have been adopted by the House and Senate, and are honored by tradition.

Jefferson's Manual, which is integral to the Rules of the House of Representatives,[16] states that impeachment is set in motion by charges made on the floor, charges proferred by a memorial, a member's resolution referred to a committee, a message from the president, or from facts developed and reported by an investigating committee of the House, it further states that a proposition to impeach is a question of high privilege in the House and at once supersedes business otherwise in order under the rules governing the order of business.

The House Practice: A Guide to the Rules, Precedents and Procedures of the House[17] is a reference source for information on the rules and selected precedents governing the House procedure, prepared by the House Parliamentarian; the manual has a chapter on the House's rules, procedures, and precedent for impeachment.

In 1974, as part of the preliminary investigation in the Nixon impeachment inquiry, the staff of the Impeachment Inquiry of the House Judiciary Committee prepared a report, Constitutional Grounds for Presidential Impeachment;[6] the primary focus of the Report is the definition of the term "high Crimes and Misdemeanors" and the relationship to criminality, which the Report traces through history from English roots, through the debates at the 1787 Constitutional Convention, and the history of the impeachments before 1974.

The 1974 report has been expanded and revised on several occasions by the Congressional Research Service, and the current version Impeachment and Removal dates from October 2015.[1] While this document is only staff recommendation, as a practical matter, today it is probably the single most influential definition of "high Crimes and Misdemeanors."

The Senate has formal "Rules and Procedures of Practice in the Senate When Sitting on Impeachment Trials."[18]

Calls for impeachment, and Congressional power to investigate[edit]

While the actual impeachment of a federal public official is a rare event, demands for impeachment, especially of presidents, are common,[19][20] going back to the administration of George Washington in the mid-1790s.

While almost all of them were for the most part frivolous and were buried as soon as they were introduced, several did have their intended effect. Treasury Secretary Andrew Mellon[21] and Supreme Court Justice Abe Fortas both resigned in response to the threat of impeachment hearings, and, most famously, President Richard Nixon resigned from office after the House Judiciary Committee had already reported articles of impeachment to the floor.

In advance of the formal resolution by the full House, the relevant committee may investigate, subpoena witnesses, and prepare a preliminary report of findings. For example:

Targets of congressional investigations have challenged the power of Congress to investigate before a formal resolution commences impeachment proceedings. For example, President Buchanan wrote to the committee investigating his administration:

I do, therefore, ... solemnly protest against these proceedings of the House of Representatives, because they are in violation of the rights of the coordinate executive branch of the Government, and subversive of its constitutional independence; because they are calculated to foster a band of interested parasites and informers, ever ready, for their own advantage, to swear before ex parte committees to pretended private conversations between the President and themselves, incapable, from their nature, of being disproved; thus furnishing material for harassing him, degrading him in the eyes of the country . . .[23]

He maintained that the House of Representatives possessed no general powers to investigate him, except when sitting as an impeaching body.

When the Supreme Court has considered similar issues, it held that the power to secure “needed information ... has long been treated as an attribute of the power to legislate. ... [The power to investigate is deeply rooted in the nation’s history:] It was so regarded in the British Parliament and in the colonial Legislatures before the American Revolution, and a like view has prevailed and been carried into effect in both houses of Congress and in most of the state Legislatures.” McGrain v. Daugherty, 273 U.S. 135, 161 (1927). The Supreme Court also held, “There can be no doubt as to the power of Congress, by itself or through its committees, to investigate matters and conditions relating to contemplated legislation.” Quinn v. United States, 349 U.S. 155, 160 (1955).

The Supreme Court has also explained that Congress has not only the power, but the duty, to investigate so it can inform the public of the operations of government:

It is the proper duty of a representative body to look diligently into every affair of government and to talk much about what it sees. It is meant to be the eyes and the voice, and to embody the wisdom and will of its constituents. Unless Congress have and use every means of acquainting itself with the acts and the disposition of the administrative agents of the government, the country must be helpless to learn how it is being served; and unless Congress both scrutinize these things and sift them by every form of discussion, the country must remain in embarrassing, crippling ignorance of the very affairs which it is most important that it should understand and direct; the informing function of Congress should be preferred even to its legislative function.[24]

House of Representatives: Impeachment[edit]

Impeachment proceedings may be requested by a member of the House of Representatives on his or her own initiative, either by presenting a list of the charges under oath or by asking for referral to the appropriate committee; the impeachment process may be requested by non-members. For example, when the Judicial Conference of the United States suggests a federal judge be impeached, a charge of actions constituting grounds for impeachment may come from a special prosecutor, the President, or state or territorial legislature, grand jury, or by petition. An impeachment proceeding formally begins with a resolution adopted by the full House of Representatives, which typically includes a referral to a House committee.

The type of impeachment resolution determines the committee to which it is referred. A resolution impeaching a particular individual is typically referred to the House Committee on the Judiciary. A resolution to authorize an investigation regarding impeachable conduct is referred to the House Committee on Rules, and then to the Judiciary Committee; the House Committee on the Judiciary, by majority vote, will determine whether grounds for impeachment exist. If the Committee finds grounds for impeachment, it will set forth specific allegations of misconduct in one or more articles of impeachment; the Impeachment Resolution, or Articles of Impeachment, are then reported to the full House with the committee's recommendations.

The House debates the resolution and may at the conclusion consider the resolution as a whole or vote on each article of impeachment individually. A simple majority of those present and voting is required for each article for the resolution as a whole to pass. If the House votes to impeach, managers (typically referred to as "House managers", with a "lead House manager") are selected to present the case to the Senate. Recently, managers have been selected by resolution, while historically the House would occasionally elect the managers or pass a resolution allowing the appointment of managers at the discretion of the Speaker of the United States House of Representatives; these managers are roughly the equivalent of the prosecution or district attorney in a standard criminal trial.

Also, the House will adopt a resolution in order to notify the Senate of its action. After receiving the notice, the Senate will adopt an order notifying the House that it is ready to receive the managers; the House managers then appear before the bar of the Senate and exhibit the articles of impeachment. After the reading of the charges, the managers return and make a verbal report to the House.

Senate: Trial[edit]

Depiction of the impeachment trial of President Andrew Johnson in 1868, Chief Justice Salmon P. Chase presiding.

The proceedings unfold in the form of a trial, with each side having the right to call witnesses and perform cross-examinations; the House members, who are given the collective title of managers during the course of the trial, present the prosecution case, and the impeached official has the right to mount a defense with his or her own attorneys as well. Senators must also take an oath or affirmation that they will perform their duties honestly and with due diligence. After hearing the charges, the Senate usually deliberates in private; the Constitution requires a two-thirds super majority to convict a person being impeached.[25] The Senate enters judgment on its decision, whether that be to convict or acquit, and a copy of the judgment is filed with the Secretary of State.[18] Upon conviction in the Senate, the official is automatically removed from office and may also be barred from holding future office; the trial is not an actual criminal proceeding and more closely resembles a civil service termination appeal in terms of the contemplated deprivation. Therefore, the removed official may still be liable to criminal prosecution under a subsequent criminal proceeding; the President may not grant a pardon in the impeachment case, but may in any resulting Federal criminal case.[26]

Beginning in the 1980s with Harry E. Claiborne, the Senate began using "Impeachment Trial Committees" pursuant to Senate Rule XI.[18] These committees presided over the evidentiary phase of the trials, hearing the evidence and supervising the examination and cross-examination of witnesses; the committees would then compile the evidentiary record and present it to the Senate; all senators would then have the opportunity to review the evidence before the chamber voted to convict or acquit. The purpose of the committees was to streamline impeachment trials, which otherwise would have taken up a great deal of the chamber's time. Defendants challenged the use of these committees, claiming them to be a violation of their fair trial rights as this did not meet the constitutional requirement for their cases to be "tried by the Senate". Several impeached judges, including District Court Judge Walter Nixon, sought court intervention in their impeachment proceedings on these grounds. In Nixon v. United States (1993), the Supreme Court determined that the federal judiciary could not review such proceedings, as matters related to impeachment trials are political questions and could not be resolved in the courts.[2]

In theory at least, as President of the Senate, the Vice President of the United States could preside over their own impeachment, although legal theories suggest that allowing a defendant to be the judge in their own case would be a blatant conflict of interest. If the Vice President did not preside over an impeachment (of anyone besides the President), the duties would fall to the President pro tempore of the Senate.

To convict an accused, "the concurrence of two thirds of the [Senators] present" for at least one article is required. If there is no single charge commanding a "guilty" vote of two-thirds majority of the senators present, the defendant is acquitted and no punishment is imposed.

Results of conviction[edit]

Conviction removes the defendant from office. Following conviction, the Senate may vote to further punish the individual by barring him or her from holding future federal office, elected or appointed. However, conviction does not extend to further punishment, for example, loss of pension. After conviction by the Senate, "the Party convicted shall nevertheless be liable and subject to Indictment, Trial, Judgment and Punishment, according to Law" in the regular federal or state courts.

History of federal constitutional impeachment[edit]

In the United Kingdom, impeachment was a procedure whereby a member of the House of Commons could accuse someone of a crime. If the Commons voted for the impeachment, a trial would then be held in the House of Lords. Unlike a bill of attainder, a law declaring a person guilty of a crime, impeachments did not require royal assent, so they could be used to remove troublesome officers of the Crown even if the monarch was trying to protect them.

The monarch, however, was above the law and could not be impeached, or indeed judged guilty of any crime; when King Charles I was tried before the Rump Parliament of the New Model Army in 1649 he denied that they had any right to legally indict him, their king, whose power was given by God and the laws of the country, saying: "no earthly power can justly call me (who is your King) in question as a delinquent ... no learned lawyer will affirm that an impeachment can lie against the King." While the House of Commons pronounced him guilty and ordered his execution anyway, the jurisdictional issue tainted the proceedings.

With this example in mind, the delegates to the 1787 Constitutional Convention chose to include an impeachment procedure in Article II, Section 4 of the Constitution which could be applied to any government official; they explicitly mentioned the President to ensure there would be no ambiguity. Opinions differed, however, as to the reasons Congress should be able to initiate an impeachment. Initial drafts listed only treason and bribery, but George Mason favored impeachment for "maladministration" (incompetence). James Madison argued that impeachment should only be for criminal behavior, arguing that a maladministration standard would effectively mean that the President would serve at the pleasure of the Senate,[27] thus the delegates adopted a compromise version allowing impeachment for "treason, bribery and other high crimes and misdemeanors".

Federal impeachment investigations formally commenced and officials impeached [edit]

The House of Representatives has initated impeachment proceedings 62 times since 1789.[citation needed]

The House has impeached 19 federal officers. Of these:

Of the 19 impeachments by the House, two cases did not come to trial because the individuals had left office, nine were acquitted, and eight officials were convicted, all of whom were judges.[29][30] One, former judge Alcee Hastings, was elected as a member of the United States House of Representatives after being removed from office.

Additionally, an impeachment process against Richard Nixon was commenced, but not completed, as he resigned from office before the full House voted on the articles of impeachment.[2] To date, no president has been removed from office by impeachment and conviction.

The following table lists federal officials for whom impeachment proceedings were instituted and referred to a committee of the House of Representatives. Numbered lines of the table reflect officials impeached by a majority vote of the House. Unnumbered lines are those officials for whom an impeachment proceeding was formally instituted, but ended when (a) the Committee did not vote to recommend impeachment, (b) the Committee recommended impeachment but the vote in the full House failed, or (c) the official resigned or died before the full House vote.

# Date of Impeachment Accused Office Accusations Result[Note 1] Refer­ences
1 July 7, 1797 William-blount-wb-cooper.jpg William Blount United States Senator (Tennessee) Conspiring to assist Britain in capturing Spanish territory Senate refused to accept impeachment of a Senator by the House of Representatives, instead expelling him from the Senate on their own authority[31][Note 2] [32]
2 March 2, 1803 John Pickering Judge (District of New Hampshire) Drunkenness and unlawful rulings Convicted; removed on March 12, 1804[31][33] [32][33]
3 March 12, 1804 Samuel Chase (bust crop).jpg Samuel Chase Associate Justice (Supreme Court of the United States) Political bias and arbitrary rulings, promoting a partisan political agenda on the bench [34] Acquitted on March 1, 1805 [31][33]
4 April 24, 1830 JamesHPeck.jpg James H. Peck Judge (District of Missouri) Abuse of power[35] Acquitted on January 31, 1831[31][33] [32][33]
March to June 1860 James Buchanan President of the United States corruption The Covode committee was established March 5, 1860, and submitted its final report on June 16, 1860. The committee found that Buchanan had not done anything to warrant impeachment, but that his was the most corrupt administration since the adoption of the US Constitution in 1789. [36][37]
5 May 6, 1862 West Hughes Humphreys.jpg West Hughes Humphreys Judge (Eastern, Middle, and Western Districts of Tennessee) Supporting the Confederacy Convicted; removed and disqualified on June 26, 1862[32][31][33] [32][33]
6 February 24, 1868 by a 126 to 47 vote President Andrew Johnson.jpg Andrew Johnson President of the United States Violating the Tenure of Office Act. The Supreme Court would later state in dicta that the (by then repealed) Tenure of Office Act had been unconstitutional.[38] Acquitted on May 26, 1868, 35–19 in favor of conviction, falling one vote short of two-thirds.[31] Impeachment of Andrew Johnson,[32]
7 February 28, 1873 Mark W. Delahay.jpg Mark W. Delahay Judge (District of Kansas) Drunkenness Resigned on December 12, 1873[33][39] [33][39]
8 March 2, 1876 WWBelknap.jpg William W. Belknap United States Secretary of War (resigned after impeachment and before trial) Graft, corruption Acquitted after his resignation on August 1, 1876.[31] [32]
9 December 13, 1904 Charles Swayne Judge (Northern District of Florida) Failure to live in his district, abuse of power[40] Acquitted on February 27, 1905[31][33] [32][33]
10 July 11, 1912 Robert W. Archbald cph.3a03594 (bust crop).jpg Robert Wodrow Archbald Associate Justice (United States Commerce Court)
Judge (Third Circuit Court of Appeals)
Improper acceptance of gifts from litigants and attorneys Convicted; removed and disqualified on January 13, 1913[32][31][33] [32][33]
11 April 1, 1926 George W. English cph.3a03600.jpg George W. English Judge (Eastern District of Illinois) Abuse of power Resigned on November 4, 1926,[32][31] proceedings dismissed on December 13, 1926[32][33] [32][33]
12 February 24, 1933 Harold Louderback Judge (Northern District of California) Corruption Acquitted on May 24, 1933[31][33] [32][33]
13 March 2, 1936 Halsted L. Ritter Judge (Southern District of Florida) Champerty, corruption, tax evasion, practicing law while a judge Convicted; removed on April 17, 1936[31][33] [32][33]
1953 William O. Douglas Associate Justice of the U.S. Supreme Court brief stay of execution for Julius and Ethel Rosenberg Referred to Judiciary Committee (Jun. 18, 1953); committee voted to end the investigation (Jul 7, 1953).
preliminary proceedings aborted before impeachment vote, January to August 1974 Richard Nixon President of the United States Obstruction of justice, Abuse of Power, Contempt of Congress House Judiciary Committee begins investigating and issuing subpoenas (Oct. 30, 1973); House Judiciary Report on committee investigation (Feb. 1, 1974)[41]; House resolution 93-803 authorizes Judiciary Committee investigation (Feb. 6, 1974)[42]; House Judiciary Committee votes three articles of impeachment to House floor (July 27–30, 1974)[43]; proceedings terminated by resignation of President Nixon (August 8, 1974).
14 July 22, 1986 Harry Claiborne (bust crop).jpg Harry E. Claiborne Judge (District of Nevada) Tax evasion Removed on October 9, 1986[31][33] [32][33]
15 August 3, 1988 Alcee Hastings Portrait c111-112th Congress.jpg Alcee Hastings Judge (Southern District of Florida) Accepting a bribe, and committing perjury during the resulting investigation Removed on October 20, 1989[31][33] [32][33]
16 May 10, 1989 Walter Nixon (bust crop).jpg Walter Nixon Chief Judge (Southern District of Mississippi) Perjury Removed on November 3, 1989[31][33][Note 3] [32][33]
17 December 19, 1998 Bill Clinton.jpg Bill Clinton President of the United States Perjury and obstruction of justice[44] Acquitted on February 12, 1999--45–55 on obstruction of justice and 50–50 on perjury[31] [45]
18 June 19, 2009 KentSamuel.jpg Samuel B. Kent Judge (Southern District of Texas) Sexual assault, and obstruction of justice during the resulting investigation Resigned on June 30, 2009,[33][46] proceedings dismissed on July 22, 2009[31][33][47] [33][48]
19 March 11, 2010 PorteousThomasG.jpg Thomas Porteous Judge (Eastern District of Louisiana) Making false financial disclosures Convicted, removed and disqualified on December 8, 2010[31][33][49] [33][50]

There have been unsuccessful attempts to initiate impeachment proceedings against John Tyler, Richard Nixon, George W. Bush, Barack Obama, and Donald Trump.

One notable impeachment attempt that never reached the point of House resolution was an attempt to impeach Associate Justice William O. Douglas by then-House Minority Leader Gerald R. Ford; the Legislative Reference Service of the Library of Congress prepared a report as part of Mr. Ford's vetting for confirmation as Vice President in 1973.[22]

President Bill Clinton, Democrat, was impeached on December 19, 1998, by the House of Representatives on articles charging perjury (specifically, lying to a federal grand jury) by a 228–206 vote and obstruction of justice by a 221–212 vote; the House rejected other articles: one was a count of perjury in a civil deposition in Paula Jones' sexual harassment lawsuit against Clinton (by a 205–229 vote); the second accused Clinton of abuse of power (by a 148–285 vote). President Clinton was acquitted by the Senate; the votes in the Senate to remove him from office did not even reach a majority, let alone two-thirds: 45–55 on obstruction of justice and 50–50 on perjury.

See also:

Impeachment in the states[edit]

State legislatures can impeach state officials, including governors, in every State except Oregon; the court for the trial of impeachments may differ somewhat from the federal model—in New York, for instance, the Assembly (lower house) impeaches, and the State Senate tries the case, but the members of the seven-judge New York State Court of Appeals (the state's highest, constitutional court) sit with the senators as jurors as well.[51] Impeachment and removal of governors has happened occasionally throughout the history of the United States, usually for corruption charges. A total of at least eleven U.S. state governors have faced an impeachment trial; a twelfth, Governor Lee Cruce of Oklahoma, escaped impeachment conviction by a single vote in 1912. Several others, most recently Missouri's Eric Greitens, have resigned rather than face impeachment, when events seemed to make it inevitable;[52] the most recent impeachment of a state governor occurred on January 14, 2009, when the Illinois House of Representatives voted 117–1 to impeach Rod Blagojevich on corruption charges;[53] he was subsequently removed from office and barred from holding future office by the Illinois Senate on January 29. He was the eighth U.S. state governor to be removed from office.

The procedure for impeachment, or removal, of local officials varies widely. For instance, in New York a mayor is removed directly by the governor "upon being heard" on charges—the law makes no further specification of what charges are necessary or what the governor must find in order to remove a mayor.

In 2018, the entire Supreme Court of Appeals of West Virginia was impeached, something that has been often threatened, but had never happened before.

State and territorial officials impeached[edit]

Date Accused Office Result
1804 William W. Irvin.jpg William W. Irvin Associate Judge, Fairfield County, Ohio, Court of Common Pleas Removed
1832 Theophilus W. Smith.jpg Theophilus W. Smith Associate Justice, Illinois Supreme Court Acquitted[54]
February 26, 1862 CRobinson.jpg Charles L. Robinson Governor of Kansas Acquitted[55]
John Winter Robinson Secretary of State of Kansas Removed on June 12, 1862[56]
George S. Hillyer State auditor of Kansas Removed on June 16, 1862[56]
1871 NCG-WilliamHolden.jpg William Woods Holden Governor of North Carolina Removed
1871 Hon. David Butler. Governor Nebraska - NARA - 528665.jpg David Butler Governor of Nebraska Removed[55]
February 1872 Governor Harrison Reed of Florida.jpg Harrison Reed Governor of Florida Acquitted[57]
March 1872 Thirty years of New York politics up-to-date (1889) (14592180978).jpg George G. Barnard Supreme Court (1st District) Removed
1872 H C Warmoth 1870s W Kurtz.jpg Henry C. Warmoth Governor of Louisiana "Suspended from office," though trial was not held[58]
1876 Gen. Adelbert Ames - NARA - 527085.jpg Adelbert Ames Governor of Mississippi Resigned[55]
1888 Honest Dick Tate.png James W. Tate Kentucky State Treasurer Removed
1901 David M. Furches Chief Justice, North Carolina Supreme Court Acquitted[59]
Robert M. Douglas Associate Justice, North Carolina Supreme Court Acquitted[59]
August 13, 1913[60] William Sulzer NY.jpg William Sulzer Governor of New York Removed on October 17, 1913[61]
July 1917 James E. Ferguson.jpg James E. Ferguson Governor of Texas Removed[62]
October 23, 1923 Jack Walton.jpg John C. Walton Governor of Oklahoma Removed
January 21, 1929 Henry S. Johnston Governor of Oklahoma Removed
April 6, 1929[63] HueyPLongGesture.jpg Huey P. Long Governor of Louisiana Acquitted
May 1958[64] Raulston Schoolfield Judge, Hamilton County, Tennessee Criminal Court Removed on July 11, 1958[65]
March 14, 1984[66] Paul L. Douglas Nebraska Attorney General Acquitted by the Nebraska Supreme Court on May 4, 1984[67]
February 6, 1988[68] Evan Mecham Governor of Arizona Removed on April 4, 1988[69]
March 30, 1989[70] A. James Manchin State treasurer of West Virginia Resigned on July 9, 1989 before trial started[71]
January 25, 1991[72] Ward "Butch" Burnette Kentucky Commissioner of Agriculture Resigned on February 6, 1991 before trial started[73]
May 24, 1994[74] Rolf Larsen Associate Justice, Pennsylvania Supreme Court Removed on October 4, 1994, and declared ineligible to hold public office in Pennsylvania[75]
October 6, 1994[76] Judith Moriarty Secretary of State of Missouri Removed by the Missouri Supreme Court on December 12, 1994[77]
November 11, 2004[78] Kathy Augustine Nevada State Controller Censured on December 4, 2004, not removed from office[79]
April 11, 2006[80] David Hergert Member of the University of Nebraska Board of Regents Removed by the Nebraska Supreme Court on July 7, 2006[81]
January 8, 2009
(first vote)[82]
Rod Blagojevich (2911120436) (cropped).jpg Rod Blagojevich Governor of Illinois 95th General Assembly ended
January 14, 2009
(second vote)[83]
Removed on January 29, 2009, and declared ineligible to hold public office in Illinois[84]
February 11, 2013[85] Benigno Fitial 2009.jpg Benigno Fitial Governor of the Northern Mariana Islands Resigned on February 20, 2013
August 13, 2018[86] Robin Davis Associate Justices, Supreme Court of Appeals of West Virginia Retired on August 13, 2018.[87] Despite her retirement, the West Virginia Senate refused to dismiss the articles of impeachment and scheduled trial for October 29, 2018 although the trial is currently delayed by court order.[88]
Allen Loughry Resigned on November 12, 2018.[89][90] Possible trial before the West Virginia Senate delayed by court order.[88]
Beth Walker Reprimanded and censured on October 2, 2018, not removed from office.[91]
Margaret Workman Chief Justice, Supreme Court of Appeals of West Virginia Trial before the West Virginia Senate delayed by court order after originally being scheduled for October 15, 2018.[92][93]

State governors[edit]

At least four state governors have been impeached and removed from office:


See also[edit]

Notes[edit]

  1. ^ "Removed and disqualified" indicates that following conviction the Senate voted to disqualify the individual from holding further federal office pursuant to Article I, Section 3 of the United States Constitution, which provides, in pertinent part, that "[j]udgment in cases of impeachment shall not extend further than to removal from office, and disqualification to hold and enjoy any office of honor, trust or profit under the United States."
  2. ^ During the impeachment trial of Senator Blount, it was argued that the House of Representatives did not have the power to impeach members of either House of Congress; though the Senate never explicitly ruled on this argument, the House has never again impeached a member of Congress. The Constitution allows either House to expel one of its members by a two-thirds vote, which the Senate had done to Blount on the same day the House impeached him (but before the Senate heard the case).
  3. ^ Judge Nixon later challenged the validity of his removal from office on procedural grounds; the challenge was ultimately rejected as nonjusticiable by the Supreme Court in Nixon v. United States, 506 U.S. 224 (1993).

References[edit]

  1. ^ a b c d e f g h i j k l m n o p Cole, J.P.; Garvey, T. (October 29, 2015). "Report No. R44260, Impeachment and Removal" (PDF). Congressional Research Service. pp. 15–16. Retrieved 22 September 2016. This article incorporates text from this source, which is in the public domain. An earlier version from 2005 is at https://www.senate.gov/reference/resources/pdf/98-806.pdf.
  2. ^ a b c Presser, Stephen B. "Essays on Article I: Impeachment". The Heritage Guide to the Constitution. Heritage Foundation. Retrieved June 14, 2018.
  3. ^ U.S. Constitution, Article II, Section 4
  4. ^ a b THE FEDERALIST No. 65 (Alexander Hamilton)
  5. ^ a b Impeachment of Walter L. Nixon, Jr., H.Rept. 101-36 at 5 (1989).
  6. ^ a b c d e Staff of the Impeachment Inquiry, Committee on the Judiciary, House of Representatives, Constitutional Grounds for Presidential Impeachment, 93rd Conf. 2nd Sess. (Feb. 1974), available at https://judiciary.house.gov/sites/democrats.judiciary.house.gov/files/1974ImpeachmentInquiryReport.pdf
  7. ^ See Impeachment of President Andrew Johnson, in Impeachment—Selected Materials, Committee on the Judiciary, 93d Cong., Impeachment—Selected Material 692 (Comm. Print 1973).
  8. ^ Bowsher v. Synar, 478 U.S. 714, 729-30 (1986)
  9. ^ "Nixon vs. United States". Illinois Institute of Technology, Chicago-Kent School of Law. Retrieved July 29, 2014.
  10. ^ Gerald Ford's Remarks on the Impeachment of Supreme Court Justice William Douglas April 15, 1970. Retrieved 21 March 2019.]
  11. ^ Ripy, Thomas B. "Standard of Proof in Senate Impeachment Proceedings". Congressional Research Service.
  12. ^ The Constitution also discusses the President's power to appoint "Officers of the United States," "the principal Officer in each of the executive Departments," and "Inferior officers." That's different.
  13. ^ a b Senate Journal, 5th Cong., 3rd Sess., Dec. 17, 1798 to Jan. 10, 1799.
  14. ^ Senate List of Impeachment trials Archived December 8, 2010, at WebCite
  15. ^ Buckner F. Milton (1998). The First Impeachment. Mercer University Press. ISBN 9780865545977.
  16. ^ "House Rules". Archived from the original on December 12, 2010. Retrieved December 31, 2010.
  17. ^ Parliamentarian of the House, U.S. House of Representatives, The House Practice: A Guide to the Rules, Precedents and Procedures of the House, at https://www.govinfo.gov/collection/house-practice. Each Congress adopts its own rules, available at https://rules.house.gov/resources
  18. ^ a b c "Rules and Procedures of Practice in the Senate When Sitting on Impeachment Trials" (PDF). Senate Manual Containing the Standing Rules, Orders, Laws and Resolutions Affecting the Business of the United States Senate, Section 100–126, 105th Congress, pp. 177–185. United States Senate. August 16, 1986. Retrieved June 14, 2018.
  19. ^ Tentative description of a dinner given to promote the impeachment of President Dwight Eisenhower: [poem] by Lawrence Ferlinghetti; City Lights Books: (1958)
  20. ^ Clark, Richard C. (2008-07-22). "McFadden's Attempts to Abortababy the Federal Reserve System". Scribd. Archived from the original on 2010-03-02. Retrieved 2009-06-20. Though a Republican, he moved to impeach President Herbert Hoover in 1932 and introduced a resolution to bring conspiracy charges against the Board of Governors of the Federal Reserve.
  21. ^ "National Affairs: Texan, Texan & Texan". Time. January 25, 1932. Retrieved May 5, 2010.
  22. ^ a b Legislative Reference Service of the Library of Congress, Role of Vice-President Designate Gerald R. Ford in the Attempt to Impeach Associate Supreme Court Justice William O. Douglas, at https://www.fordlibrarymuseum.gov/library/document/0023/1687418.pdf
  23. ^ James Buchanan, The Works of James Buchanan Vol. XII 225–26 (John Bassett Moore ed., J.B. Lippincott Company) (1911)
  24. ^ United States v. Rumely, 345 U.S. 41, 43 (1953), quoting Woodrow Wilson, Congressional Government: A Study in American Politics, 303.
  25. ^ "What would Trump have to do to get impeached?". whatifhq.com. Retrieved 2018-08-26.
  26. ^ Gerhardt, Michael J. "Essays on Article I: Punishment for Impeachment". The Heritage Guide to the Constitution. Heritage Foundation. Retrieved June 14, 2018.
  27. ^ "Welcome to The American Presidency". Archived from the original on 2007-09-30. Retrieved 2007-04-20.
  28. ^ Erskine, Daniel H. (2008). "The Trial of Queen Caroline and the Impeachment of President Clinton: Law As a Weapon for Political Reform". Washington University Global Studies Law Review. 7 (1). ISSN 1546-6981.
  29. ^ "U.S. Senate: Impeachment". www.senate.gov. Retrieved 2018-09-19.
  30. ^ "Impeachment History". Infoplease. Retrieved 2013-07-12.
  31. ^ a b c d e f g h i j k l m n o p q r "Chapter 4: Complete List of Senate Impeachment Trials". United States Senate. Archived from the original on 2010-12-08. Retrieved 2010-12-08.CS1 maint: BOT: original-url status unknown (link) ()
  32. ^ a b c d e f g h i j k l m n o p q r U.S. Joint Committee on Printing (September 2006). "Impeachment Proceedings". Congressional Directory. Retrieved 2009-06-19. (Archived by WebCite)
  33. ^ a b c d e f g h i j k l m n o p q r s t u v w x y z aa ab ac ad "Impeachments of Federal Judges". Federal Judicial Center. Retrieved 2017-05-16.
  34. ^ "1801: Senate Tries Supreme Court Justice". November 25, 2014.
  35. ^ PBS NewsHour
  36. ^ Baker, Jean H.: James Buchanan; Times Books, 2004
  37. ^ U.S. House Journal, 36th Congress, 1st session, Page 450
  38. ^ Myers v. United States, 272 U.S. 52 (1926)
  39. ^ a b "Judges of the United States Courts – Delahay, Mark W." Federal Judicial Center. Retrieved 2009-06-20.
  40. ^ "Hinds' Precedents, Volume 3 – Chapter 78 – The Impeachment and Trial of Charles Swayne".
  41. ^ House Rept 93–774
  42. ^ House Res. 93-803, Resolution providing appropriate power to the Committee on the Judiciary to conduct an investigation of whether sufficient grounds exist to impeach Richard M. Nixon, President of the United States
  43. ^ House Report 93-1305, Report of the Committee on the Judiciary, Impeachment of Richard M. Nixon, President of the United States
  44. ^ https://www.congress.gov/congressional-report/105th-congress/house-report/830 House Report 105-830 – Impeachment of William Jefferson Clinton, President of the United States
  45. ^ Erskine, Daniel H (2008). "The Trial of Queen Caroline and the Impeachment of President Clinton: Law As a Weapon for Political Reform". Washington University Global Studies Law Review. Washington University in St. Louis. Archived from the original on March 27, 2019. Retrieved April 8, 2019.
  46. ^ Gamboa, Suzanne (2009-06-30). "White House accepts convicted judge's resignation". Associated Press. Archived from the original on July 23, 2009. Retrieved 2009-07-22.CS1 maint: BOT: original-url status unknown (link)
  47. ^ Gamboa, Suzanne (2009-07-22). "Congress ends jailed judge's impeachment". Associated Press. Archived from the original on September 27, 2010. Retrieved 2010-12-08.CS1 maint: BOT: original-url status unknown (link)
  48. ^ Powell, Stewart (2009-06-19). "U.S. House impeaches Kent". Houston Chronicle. Archived from the original on June 20, 2009. Retrieved 2009-06-19. In action so rare it has been carried out only 14 times since 1803, the House on Friday impeached a federal judge—imprisoned U.S. District Court Judge Samuel B. Kent...CS1 maint: BOT: original-url status unknown (link)
  49. ^ Alpert, Bruce; Tilove, Jonathan (2010-12-08). "Senate votes to remove Judge Thomas Porteous from office". New Orleans Times-Picayune. Retrieved 2010-12-08.
  50. ^ Alpert, Bruce (2010-03-11). "Judge Thomas Porteous impeached by U.S. House of Representatives". New Orleans Times-Picayune. Retrieved 2010-03-11.
  51. ^ NYS Constitution, Article VI, § 24
  52. ^ Suntrup, Jack; Erickson, Kurt. "Embattled Gov. Eric Greitens resigns". St. Louis Post-Dispatch.
  53. ^ "House votes to impeach Blagojevich again". Chicago Tribune. 2009-01-14. Retrieved 2009-01-14.
  54. ^ Bateman, Newton; Selby, Paul; Shonkwiler, Frances M.; Fowkes, Henry L. (1908). Historical Encyclopedia of Illinois. Chicago, IL: Munsell Publishing Company. p. 489.
  55. ^ a b c "Impeachment of State Officials". Cga.ct.gov. Retrieved 2008-09-06.
  56. ^ a b Blackmar, Frank (1912). Kansas: A Cyclopedia of State History. Standard Publishing Co. p. 598.
  57. ^ "Letters Relating to the Efforts to Impeach Governor Harrison Reed During the Reconstruction Era". floridamemory.com. Archived from the original on 2016-05-29. Retrieved 2016-11-04.
  58. ^ "State Governors of Louisiana: Henry Clay Warmoth". Enlou.com. Archived from the original on 2008-04-06. Retrieved 2008-09-06.
  59. ^ a b News & Observer: NC's dark impeachment history by Rob Christensen
  60. ^ "Sulzer Impeached by Assembly But Refuses to Surrender Office", Syracuse Herald, August 13, 1913, p. 1
  61. ^ "High Court Removes Sulzer from Office by a Vote of 43 to 12", Syracuse Herald, October 17, 1913, p. 1
  62. ^ Block, Lourenda (2000). "Permanent University Fund: Investing in the Future of Texas". TxTell (University of Texas at Austin). Archived from the original on 2009-02-04. Retrieved 2009-02-14.
  63. ^ Official Journal of the House of Representatives of the State of Louisiana, April 6, 1929 pp. 292–94
  64. ^ "Raulston Schoolfield, Impeached Judge, Dies". UPI. October 8, 1982. Retrieved 2016-01-27.
  65. ^ "Impeachment Trial Finds Judge Guilty". AP. July 11, 1958. Retrieved 2016-01-27.
  66. ^ "Attorney General is Impeached". AP. 1984-03-14. Retrieved 2012-10-11.
  67. ^ "Nebraskan Found Not Guilty". AP. 1984-05-04. Retrieved 2012-10-11.
  68. ^ Gruson, Lindsey (1988-02-06). "House Impeaches Arizona Governor". The New York Times. Retrieved 2009-07-02.
  69. ^ Gruson, Lindsey (1988-04-05). "Arizona's Senate Ousts Governor, Voting Him Guilty of Misconduct". The New York Times. Retrieved 2009-07-02.
  70. ^ AP staff reporter (1989-03-30). "Impeachment in West Virginia". The New York Times. Retrieved 2009-10-17.
  71. ^ Wallace, Anise C. (1989-07-10). "Treasurer of West Virginia Retires Over Fund's Losses". The New York Times. Retrieved 2009-10-17.
  72. ^ "Kentucky House Votes To Impeach Jailed Official". Orlando Sentinel. 1991-01-26. Retrieved 2015-11-16. The House voted unanimously Friday to impeach the agriculture commissioner six days after he began serving a one-year sentence for a payroll violation.
  73. ^ "Jailed Official Resigns Before Impeachment Trial". Orlando Sentinel. 1991-02-07. Retrieved 2015-11-16. Kentucky's commissioner of agriculture, serving a one-year jail sentence for felony theft, resigned Wednesday hours before his impeachment trial was scheduled to begin in the state Senate.
  74. ^ Hinds, Michael deCourcy (1994-05-25). "Pennsylvania House Votes To Impeach a State Justice". The New York Times. Retrieved 2010-01-24. A State Supreme Court justice convicted on drug charges was impeached today by the Pennsylvania House of Representatives.
  75. ^ Moushey, Bill; Tim Reeves (1994-10-05). "Larsen Removed Senate Convicts Judge On 1 Charge". Pittsburgh Post-Gazette. Pittsburgh, PA. p. A1. Retrieved 2013-09-14. Rolf Larsen yesterday became the first justice of the Pennsylvania Supreme Court to be removed from office through impeachment. The state Senate, after six hours of debate, found Larsen guilty of one of seven articles of impeachment at about 8:25 p.m, then unanimously voted to remove him permanently from office and bar him from ever seeking an elected position again.
  76. ^ Young, Virginia (1994-10-07). "Moriarty Is Impeached – Secretary Of State Will Fight Removal". St. Louis Post-Dispatch. St. Louis, MO. p. 1A. Retrieved 2013-09-14. The House voted overwhelmingly Thursday to impeach Secretary of State Judith K. Moriarty for misconduct that "breached the public trust"; the move, the first impeachment in Missouri in 26 years, came at 4:25 p.m. in a hushed House chamber.
  77. ^ Young, Virginia; Bell, Kim (1994-12-13). "High Court Ousts Moriarty". St. Louis Post-Dispatch. St. Louis, MO. p. 1A. Retrieved 2013-09-14. In a unanimous opinion Monday, the Missouri Supreme Court convicted Secretary of State Judith K. Moriarty of misconduct and removed her from office.
  78. ^ Vogel, Ed (2004-11-12). "Augustine impeached". Review-Journal. Retrieved 2009-07-02.
  79. ^ Whaley, Sean (2004-12-05). "Senate lets controller keep job". Review-Journal. Retrieved 2009-07-02.
  80. ^ Jenkins, Nate (2006-04-11). "Hergert impeached". Lincoln Journal Star. Retrieved 2012-10-11. With the last vote and by the slimmest of margins, the Legislature did to University of Nebraska Regent David Hergert Wednesday what it hadn't done in 22 years—move to unseat an elected official.
  81. ^ "Hergert Convicted". WOWT-TV. 2006-08-08. Archived from the original on 2013-01-15. Retrieved 2012-10-11. University of Nebraska Regent David Hergert was convicted Friday of manipulating campaign-finance laws during his 2004 campaign and then lying to cover it up. The state Supreme Court ruling immediately removed Hergert, 66, from office.
  82. ^ Staff reporter (2009-01-09). "Illinois House impeaches Gov. Rod Blagojevich". AP. Retrieved 2009-07-02.
  83. ^ Mckinney, Dave; Wilson, Jordan (2009-01-14). "Illinois House impeaches Gov. Rod Blagojevich". Chicago Sun-Times. Archived from the original on 2009-02-01. Retrieved 2009-07-02.
  84. ^ Long, Ray; Rick Pearson (2009-01-30). "Blagojevich is removed from office". Los Angeles Times. Retrieved 2009-06-21.
  85. ^ Eugenio, Haidee V. (2009-01-09). "CNMI governor impeached on 13 charges". Saipan Tribune. Retrieved 2013-09-14.
  86. ^ "The Latest: All 4 West Virginia justices impeached". Herald-Dispatch. Associated Press. 2018-08-13. Retrieved 2018-08-14.
  87. ^ "WV Supreme Court Justice Robin Davis retires after her impeachment". Herald-Dispatch. Associated Press. 2018-08-14. Retrieved 2018-08-14.
  88. ^ a b Effort to remove convicted Justice Loughry from office continues
  89. ^ "The Latest: W.Va. lawmakers won't meet after justice resigns". Associated Press. November 11, 2018.
  90. ^ Allen Adams, Steven (November 12, 2018). "Facing Possible Impeachment, West Virginia Supreme Court Justice Resigns". Governing.
  91. ^ MetroNews, WSAZ News Staff, WV. "Senators reprimand Justice Walker, but vote to not impeach". www.wsaz.com. Retrieved 2019-03-01.
  92. ^ writer, Phil Kabler Staff. "With Workman impeachment trial blocked, Senate debates next move". Charleston Gazette-Mail. Retrieved 2019-03-01.
  93. ^ MORRIS, JEFF (2018-10-11). "West Virginia Supreme Court halts impeachment trial for Justice Workman". WCHS. Retrieved 2019-03-01.
  94. ^ O'Dell, Larry. "WALTON, JOHN CALLOWAY (1881–1949)", Encyclopedia of Oklahoma History and Culture Archived April 16, 2009, at the Wayback Machine. (accessed July 2, 2013)
  95. ^ Watkins, Ronald J. (1990). High Crimes and Misdemeanors: The Term and Trials of Former Governor Evan Mecham. New York: William Morrow & Co. ISBN 978-0-688-09051-7.
  96. ^ Saulny, Susan (2009-01-09). "Illinois House Impeaches Governor". The New York Times. Retrieved April 21, 2009.

Further reading[edit]

External links[edit]