Constitutional provisionsArticle I, Section 2, Clause 5 of the United States Constitution provides: Article I, Section 3, Clauses 6 and 7 provide: Article II, Section 2 provides: Article II, Section 4 provides:
Impeachable offensesThe Constitution limits grounds of impeachment to "Treason, Bribery, or other high Crimes and Misdemeanors", but does not itself define "high crimes and misdemeanors".
Types of conductCongressional 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".Staff of the Impeachment Inquiry, Committee on the Judiciary, House of Representatives, ''Constitutional Grounds for Presidential Impeachment'', 93rd Conf. 2nd Sess. (Feb. 1974)
High crimes and misdemeanors"High crimes and misdemeanors", in the legal and common parlance of England in the 17th and 18th centuries, is corrupt activity by those who have special duties that are not shared with common persons. Toward the end of the 18th century, "High crimes and misdemeanors" acquired a more technical meaning. As Blackstone says in his '' Commentaries'': The first and principal high misdemeanor...was mal-administration of such high offices as are in public trust and employment. The phrase "high crimes and misdemeanors" was a common phrase when the U.S. Constitution was written and did not require any stringent or difficult criteria for determining guilt, but meant the opposite. The crimes are called "high crimes" because they are carried out by a person in a position of public authority, or by misusing the position of public authority they have been given. It does not mean that the crimes themselves are unusual or "higher" types of crime. The phrase was historically used to cover a very broad range of crimes. In 1974 the Senate's Judiciary Committee's stated that "'High Crimes and Misdemeanors' has traditionally been considered a ' ', like such other constitutional phrases as 'levying war' and 'due process.' Several commentators have suggested that 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. In 1970, then- 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."
Historical examplesOf the 21 impeachments voted by the House: * No official has been charged with treason * Three officials have been charged with bribery ** Robert W. Archbald - tried, removed ** - tried, removed ** William W. Belknap - resigned prior to impeachment, later acquitted * The remaining charges against all the other officials fall under the category of "high Crimes and Misdemeanors".
Standard of proofThe 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 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 , for which the reasonable doubt standard was set.
Criminal vs non-criminal activityIn drawing up articles of impeachment, the House has placed little emphasis on criminal conduct. 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. Officials have been impeached and removed for drunkenness, biased decision-making, or inducing parties to enter financial transactions, none of which is specifically criminal. Two of the articles against President were based on rude speech that reflected badly on the office: President Johnson 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". A number of individuals have been impeached for behavior incompatible with the nature of the office they hold. Some impeachments have addressed, at least in part, conduct before the individuals assumed their positions: for example, Article IV against Judge related to false statements to the and Senate in connection with his nomination and confirmation to the court. 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".
Who can be impeachedThe Constitution gives Congress the authority to impeach and remove "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". Federal judges are subject to impeachment. In fact, 15 of 20 officers impeached, and all eight officers removed after Senate trial, have been judges. The most recent impeachment effort against a Supreme Court justice that resulted in a House of Representatives investigation was against Associate Justice . In 1970, Representative Gerald R. Ford (R-MI), who was then House minority leader, called for the House to impeach Douglas. However, a House investigation led by Congressman (D-NY) determined that Ford's allegations were baseless. According to Professor Joshua E. Kastenberg at the University of New Mexico, School of Law, Ford and Nixon sought to force Douglas off the Court in order to cement the " " as well as to provide cover for the invasion of Cambodia. 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. 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.Senate Journal, 5th Cong., 3rd Sess., December 17, 1798 to January 10, 1799. 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 Behavior, and, with the Concurrence of two thirds, expel a Member." (''see 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 of Tennessee. The Senate expelled Senator Blount under Article I, Section 5, on the same day. However, the impeachment proceeding remained pending (expulsion only removes the individual from office, but conviction after impeachment may also bar 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. The House has not impeached a Member of Congress since. The constitutional text is silent on whether an officer can be tried after the officer resigns or his/her term ends. However, as the 1876 case of William W. Belknap illustrates, when the issue has arisen, the House has been willing to impeach after resignation, and the Senate has been willing to try the official after resignation.
ProcedureAt the federal level, the impeachment process is a three-step procedure.''Impeachment and Removal''
RulesA 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, states that impeachment is set in motion by charges made on the floor, charges proffered 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'' 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''. 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. 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''.
Calls for impeachment, and Congressional power to investigateWhile the actual impeachment of a federal public official is rare, demands for impeachment, especially of presidents, are common, going back to the administration of in the mid-1790s. While almost all of them were for the most part frivolous and were abandoned as soon as they were introduced, several did have their intended effect. Treasury Secretary and Supreme Court Justice both resigned in response to the threat of impeachment hearings, and most famously, President 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 to authorize proceedings, committee chairmen have the same power for impeachment as for any other issue within the jurisdiction of the committee: to investigate, subpoena witnesses, and prepare a preliminary report of findings. For example: * In 1970, House minority leader Gerald R. Ford attempted to initiate impeachment proceedings against Associate Justice ; the attempt included a 90-minute speech on the House floor.Legislative Reference Service of the Library of Congress
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...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.... he 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'', . 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." The Supreme Court considered the power of the Congress to investigate, and to subpoena executive branch officials, in a pair of cases arising out of alleged corruption in the administration of President . In the first, '' McGrain v. Daugherty'', the Court considered a subpoena issued to the brother of Attorney General Harry Daugherty for bank records relevant to the Senate's investigation into the Department of Justice. Concluding that the subpoena was valid, the Court explained that Congress's "power of inquiry... is an essential and appropriate auxiliary to the legislative function", as " legislative body cannot legislate wisely or effectively in the absence of information respecting the conditions which the legislation is intended to affect or change." The Supreme Court held that it was irrelevant that the Senate's authorizing resolution lacked an "avow lthat legislative action was had in view" because, said the Court, "the subject to be investigated was... ainly subject... on which legislation could be had" and such legislation "would be materially aided by the information which the investigation was calculated to elicit." Although " express avowal" of the Senate's legislative objective "would have been better", the Court admonished that "the presumption should be indulged that egislationwas the real object." Two years later, in ''Sinclair v. United States'', the Court considered investigation of private parties involved with officials under potential investigation for public corruption. In ''Sinclair'', Harry F. Sinclair, the president of an oil company, appealed his conviction for refusing to answer a Senate committee's questions regarding his company's allegedly fraudulent lease on federal oil reserves at Teapot Dome in Wyoming. The Court, acknowledging individuals' "right to be exempt from all unauthorized, arbitrary or unreasonable inquiries and disclosures in respect of their personal and private affairs", nonetheless explained that because " was a matter of concern to the United States, ... the transaction purporting to lease to inclair's companythe lands within the reserve cannot be said to be merely or principally... personal." The Court also dismissed the suggestion that the Senate was impermissibly conducting a criminal investigation. "It may be conceded that Congress is without authority to compel disclosures for the purpose of aiding the prosecution of pending suits," explained the Court, "but the authority of that body, directly or through its committees, to require pertinent disclosures in aid of its own constitutional power is not abridged because the information sought to be elicited may also be of use in such suits." The Supreme Court reached similar conclusions in a number of other cases. In '' Barenblatt v. United States'', the Court permitted Congress to punish contempt, when a person refused to answer questions while testifying under subpoena by the House Committee on Un-American Activities. The Court explained that although "Congress may not constitutionally require an individual to disclose his ... private affairs except in relation to ... a valid legislative purpose", such a purpose was present. Congress's "wide power to legislate in the field of Communist activity... and to conduct appropriate investigations in aid thereof is hardly debatable," said the Court, and "[s]o long as Congress acts in pursuance of its constitutional power, the Judiciary lacks authority to intervene on the basis of the motives which spurred the exercise of that power." Presidents have often been the subjects of Congress's legislative investigations. For example, in 1832, the House vested a select committee with subpoena power "to inquire whether an attempt was made by the late Secretary of War... fraudulently .. a contract for supplying rations" to Native Americans and to "further... inquire whether the President... had any knowledge of such attempted fraud, and whether he disapproved or approved of the same." In the 1990s, first the House and Senate Banking Committees and then a Senate special committee investigated President and Mrs. Clinton's involvement in the Whitewater land deal and related matters. The Senate had an enabling resolution; the House did not. 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:
House of Representatives: ImpeachmentImpeachment 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 . The impeachment process may be requested by non-members. For example, when the suggests a federal judge be impeached, a charge of actions constituting grounds for impeachment may come from a , the president, or state or territorial legislature, , or by . 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 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 (this vote is not law and is not required, US Constitution and US law).
Articles of impeachmentWhere 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 . 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 trialSenate rules call for an impeachment trial to begin at 1 pm on the day after articles of impeachment are delivered to the Senate, except for Sundays. There is no timeframe requirement for when the managers must actually deliver the articles of impeachment to the Senate. On the set date, senators are sworn in for the impeachment trial. The proceedings take the form of a trial, with the Senate having the right to call witnesses and each side having the right to perform s. The House members, who are given the collective title of managers during 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 or that they will perform their duties honestly and with . After hearing the charges, the Senate usually deliberates in private. The Constitution requires a two-thirds supermajority to convict a person being impeached. 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. Upon conviction in the Senate, the official is automatically removed from office and may by a separate vote also be barred from holding future office. The Senate 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 (unless it is the president who is convicted and thus loses the pardon power). However, whether the president can self-pardon for criminal offenses is an open question, which has never been reviewed by a court. Beginning in the 1980s with Harry E. Claiborne, the Senate began using "Impeachment Trial Committees" pursuant to Senate Rule XI. 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 intervention in their impeachment proceedings on these grounds. In '' Nixon v. United States'' (1993),'' Nixon v. United States'', . the determined that the federal judiciary could not review such proceedings, as matters related to impeachment trials are s and could not be resolved in the courts. In the case of impeachment of the president, the chief justice of the Supreme Court presides over the trial. The Constitution is silent about who would preside in the case of the impeachment of a vice president. It is doubtful the vice president would be permitted to preside over their own trial. As president of the Senate, the vice president would preside over other impeachments. If the vice president did not preside over an impeachment (of anyone besides the president), the duties would fall to the . To convict an accused, "the concurrence of two thirds of the enatorspresent" for at least one article is required. If there is no single charge commanding a "guilty" vote from two-thirds of the senators present, the defendant is acquitted and no punishment is imposed.
Removal and disqualificationConviction immediately removes the defendant from office. Following the vote on conviction, the Senate may by a separate vote also bar the individual from holding future federal office, elected or appointed. As the threshold for disqualification is not explicitly mentioned in the Constitution, the Senate has taken the position that disqualification votes only require a simple majority rather than a two-thirds supermajority. The Senate has used disqualification sparingly, as only three individuals have been disqualified from holding future office. 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. However, the Former Presidents Act of 1958, which provides a pension and other benefits, does not extend to presidents who were removed from office following an impeachment conviction. Because of an amendment to that law in 2013, a former president who has been removed from office due to impeachment and conviction is still guaranteed lifetime United States Secret Service, Secret Service protection.
History of federal constitutional impeachmentIn 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 of England, 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 (United States), Constitutional Convention chose to include an impeachment procedure in Article II, Section4 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. Thus the delegates adopted a compromise version allowing impeachment by the House for "treason, bribery and other high crimes and misdemeanors" and conviction by the Senate only with the concurrence of two-thirds of the senators present.
List of formal impeachmentsThe House has approved articles of impeachment 21 times for 20 federal officers. Of these: * Fifteen were United States federal judge, federal judges: thirteen United States district court, district court judges, one United States court of appeals, court of appeals judge (who also sat on the United States Commerce Court, Commerce Court), and one Associate Justice of the Supreme Court of the United States, associate justice of the * Three were sitting presidents: , Bill Clinton, and Donald Trump (impeached twice). * One was a United States Cabinet, Cabinet secretary * One was a United States Senate, U.S. Senator. Of the 21 impeachments by the House, eight defendants were convicted and removed from office, four cases did not come to trial because the individuals had left office and the Senate did not pursue the case, and nine ended in acquittal. To date, every convicted official was a federal judge. Of the eight to have been convicted and removed, three were disqualified from ever holding federal office again by the Senate. One of the remaining five is former congressman (D-Florida), who was convicted and removed from office as a federal judge in 1989, but was not barred from holding federal office, only to be elected to the United States House of Representatives in 1992, a seat he held until his death on April 6th, 2021. No president impeached by the House has been convicted by the Senate. In two cases, a Senate majority voted to convict an impeached president, but the vote fell short of the required two-thirds majority and therefore the impeached president was not convicted. The two instances where this happened were the Senate trial of Andrew Johnson in 1868 (where Johnson escaped conviction by one vote), and the second Senate trial of Donald Trump in 2021, where Trump missed conviction by 10 votes. The following table lists federal officials who were impeached. Blue highlight indicates presidents of the United States.
Other impeachment investigationsThe House of Representatives has initiated impeachment proceedings 63 times since 1789. 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. To date, no president or vice president has been removed from office by impeachment and conviction. Below is an incomplete list of impeachment investigations that did not lead to formal charges passing the House. Blue highlight indicates President of the United States. There have been several unsuccessful attempts to initiate impeachment proceedings against presidents, including John Tyler#Impeachment attempt, John Tyler (impeachment defeated in the House, 83–127), Efforts to impeach George W. Bush, George W. Bush, and Efforts to impeach Barack Obama, Barack Obama.
Impeachment in the statesState 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. Impeachment and removal of governors has happened occasionally throughout the history of the United States, usually for corruption charges. At least eleven U.S. state governors have faced an impeachment trial; a twelfth, Governor of Oklahoma, Governor Lee Cruce of Oklahoma, escaped impeachment by one vote in 1912. Several others, most recently Missouri's Eric Greitens, have resigned rather than face impeachment, when events seemed to make it inevitable. 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 Rod Blagojevich corruption charges, corruption charges; 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 Impeachment of the Supreme Court of Appeals of West Virginia, 2018, impeached, something that has been often threatened, but had never happened before.
State and territorial officials impeached
State governorsAt least five state governors have been impeached and removed from office: * William Sulzer, Democratic Governor of New York; false report, perjury, and suborning perjury; convicted and removed October 1913. * James E. Ferguson, Democratic Governor of Texas, was impeached for misapplication of public funds and embezzlement. In July 1917, Ferguson was convicted and removed from office. * Jack C. Walton, Democratic Party (United States), Democratic Governor of Oklahoma, was impeached for a variety of crimes including illegal collection of campaign funds, padding the public payroll, suspension of habeas corpus, excessive use of the pardon power, and general incompetence. In November 1923, Walton was convicted and removed from office. * Evan Mecham, Republican Party (United States), Republican Governor of Arizona, was impeached for obstruction of justice and misusing government funds and removed from office in April 1988. * Rod Blagojevich, Democratic Party (United States), Democratic Governor of Illinois, was impeached for abuse of power and corruption, including an attempt to sell the appointment to the United States Senate seat vacated by the resignation of Barack Obama. He was removed from office in January 2009.
Notes* Stephen B. Presser, ''Essays on Article I: Impeachment''
Further reading* * * *