Clinton v. JonesSupreme Court of the United States, 1997. 520 U.S. 681.
Facts: In 1991, the petitioner, William Jefferson Clinton, then governor of Arkansas, gave a speech at an official conference taking place a hotel. The respondent, Paula Corbin Jones, an employee of the Arkansas industrial Commission at the time, was working at the conference. Clinton sent as Arkansas state police officer to ask her to his hotel room. While she was there, Clinton made unwelcome sexual advances to Jones. Her rejection of these advances allegedly led to penalization in her government job. From 1992 to 2001, the petitioner was president. In 1994, the respondent sued Clinton for the federal law charges of acting under the color of state law to deprive her of Constitutional rights and conspiracy to deprive her of her federal rights, and the state law charges of intentional infliction of emotional distress and defamation. The petitioner filed a motion to dismiss the case on the grounds of presidential immunity until he was no longer president, arguing that unless immunity is available, the threat of judicial interference with the Executive branch would violate separation of powers principles. The respondent countered that there was no precedent for the president’s position, and that the case did not pose any threat to the presidential office. The U.S. District Court for the Eastern District of Arkansas denied the motion to dismiss on immunity grounds, ruling that discovery could go forward, but staying the trial until the end of the petitioner’s presidency. Both parties appealed. The U.S. Court of Appeals for the Eighth Circuit affirmed the dismission denial, but reversed the order postponing the trial because it was the “functional equivalent” of an unconstitutional grant of temporary immunity. The president appealed.
Issue: Does the Constitution require that the president is granted temporary immunity from private civil lawsuits?
Decision: No. Separation of powers does not require that federal courts afford the President temporary immunity from all private civil lawsuits until he leaves office. The Supreme Court affirmed the decisions of the lower courts to deny the dismissal motion. The court also affirmed the decision of the Court of Appeals reversing District Court’s order to delay the trial.
Reason:Presidential immunity applies only to official acts. It is intended to ensure that the functions of the office are performed without fear of personal liability. Thus, unofficial acts are not protected.
Separation of powers does not require temporary immunity. Separation of powers is intended to keep each of the three equal branches of government from gaining authority at the expense of another. The courts would not be gaining any new power. They would be exercising the powers granted them in Article III of the Constitution.
The judiciary’s exercise of this power in neither this case nor any resulting cases would unduly burden the President or prevent him from carrying out his official duties. There have been scant lawsuits against presidents historically, such lawsuits are usually resolved quickly, and the issues in this case are relatively unique. Moreover, the judiciary may severely burden the President when it reviews the legality of his official conduct.
The district court abused its discretion when it stayed the case because the court lacked the information to determine whether a stay would even be necessary after discovery and did not consider the respondent’s interest in a quick trial and the loss of evidence a delay might bring. However, the stay was not “the ‘functional equivalent’ of a grant of temporary immunity” because the district court has discretion to stay proceedings as part of it’s power to control it’s own docket, because they ordered discovery proceed, and because possible burdens placed on the president must be considered.
Any problems the President may have with any resulting frivolous lawsuits or difficulty pursuing the case may be handled by either federal courts or Congress, should the problem arise.