United States v. Nixon

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Following is the case brief for United States v. Nixon, United States Supreme Court, (1974)

Case summary for United States v. Nixon:

  • President Nixon was served a subpoena duces tecum after white house staff members were charged with conspiracy.
  • Nixon claimed his presidential privilege shielded him from produced the requested tapes and documents.
  • The district court found for the U.S. and Nixon appealed to the Supreme Court.
  • The Court held that the presidential communications privilege (executive privilege) is not absolute and Nixon’s general interest in confidentiality cannot trump the judicial interest of justice in receiving all relevant evidence in a criminal proceeding.

United States v. Nixon Case Brief

Statement of the facts:

A special prosecutor served President Richard Nixon with a subpoena duces tecum after certain white house staff members were federally charged with conspiracy to defraud the U.S. The court subpoenaed documents and recordings related to meeting for which the president was present. In response to the subpoena’s, Nixon claimed the presidential privilege and filed a motion to quash the subpoena. The district court denied the claim and issued a stay. While the case was in the jurisdiction of the appellate court, the Nixon filed a writ of certiorari.

Procedural History:

Nixon appealed and filed a writ of certiorari to the Supreme Court of the United States.

Rule of Law or Legal Principle Applied:

Presidential privilege of a general interest in confidentiality cannot trump judicial interest in the production of relevant evidence in a criminal trial.

 

Issue and Holding:

Whether a President can assert an absolute privilege over confidential communication in a criminal proceeding?  No.

Judgment:

The Supreme Court of the United States affirmed the district court’s decision to deny the President’s motion to quash the subpoena.

Reasoning:

The Court held that the presidential privilege is not absolute. The presidential privilege for confidential communications that do not concern the military, diplomacy or sensitive national security secrets may be rebutted as a result of the constitutional requirement to produce all relevant evidence in criminal cases. The Court stated that a general claim of presidential privilege based on public interest in confidentiality will not overcome the interest of justice in producing all evidence that is relevant.

Here, the President fails to base his claim of privilege on military, diplomacy, or national security. The Court determined that the confidentiality claim is a generalized presidential privilege and that type of claim does not outweigh the interests of justice.

Significance:

This case outlined that the presidential privilege is not absolute in nature. The privilege does not extend to confidential communications that constitute relevant evidence in a criminal proceeding.

Student Resources:

http://caselaw.findlaw.com/us-supreme-court/418/683.html
https://www.law.cornell.edu/supremecourt/text/418/683