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Trump v. Mazars USA

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Supreme Court of the United States
Trump v. Mazars USA
Term: 2019
Important Dates
Argument: May 12, 2020
Decided: July 9, 2020
Outcome
Vacated and remanded
Vote
7-2
Majority
Chief Justice John G. Roberts • Ruth Bader Ginsburg • Stephen Breyer • Sonia Sotomayor • Elena Kagan • Neil Gorsuch • Brett Kavanaugh
Dissenting
Clarence Thomas • Samuel Alito


Trump v. Mazars USA is a case argued before the Supreme Court of the United States on May 12, 2020, during the court's October 2019-2020 term. The case came on a writ of certiorari to the United States Court of Appeals for the District of Columbia Circuit. The case was consolidated with Trump v. Deutsche Bank AG.[1][2]

The court vacated the D.C. Circuit's decision in a 7-2 ruling and remanded the case. The court held that the lower courts (the D.C. Circuit and the 2nd Circuit) did not adequately consider whether congressional subpoenas requesting information from the president raise separation of powers concerns.[3] Click here for more information.

Oral argument was initially scheduled for March 31, 2020. However, the U.S. Supreme Court announced on March 16 that it was postponing the 11 oral arguments originally scheduled during its March sitting. In a press release, the court said the delay was "in keeping with public health precautions recommended in response to COVID-19."[4] COVID-19 was the abbreviation for coronavirus disease 2019, caused by SARS-CoV-2. On April 15, the court announced it had rescheduled the case for May 12, 2020.

  • Click here for more information about the court's response to the coronavirus pandemic.
  • Click here for more information about political responses to the pandemic.
HIGHLIGHTS
  • The case: In both cases, certain U.S. House committees issued subpoenas requesting financial documents. One subpoena was issued to President Donald Trump's (R) accounting firm, Mazars USA, LLP ("Mazars"). Two others were each issued to Deutsche Bank and the Capital One Financial Corporation. The president, acting in his individual capacity, challenged the subpoenas' validity in federal district court. In each case, the district court ruled in favor of the U.S. House committees. The president appealed to federal circuit courts, which upheld the district courts' decisions in both cases. Click here for more details about Trump v. Mazars USA and here for more information about Trump v. Deutsche Bank AG.
  • The issue: Whether the U.S. House Oversight and Reform Committee, Financial Services Committee, and Intelligence Committee have the "constitutional and statutory authority to issue" subpoenas to President Trump's accountant and to the president's creditors "demanding private financial records belonging to the president."[5][6]
  • The outcome: The court vacated the D.C. Circuit's decision in a 7-2 ruling and remanded the case. The court held that the lower courts (the D.C. Circuit and the 2nd Circuit) did not adequately consider whether congressional subpoenas requesting information from the president raise separation of powers concerns.[3]


    • You can review the lower court's opinion here for the D.C. Circuit and here for the 2nd Circuit.

    Timeline

    The following timeline details key events in Trump v. Mazars USA:

    The following timeline details key events in Trump v. Deutsche Bank AG:

    Background

    Trump v. Mazars USA

    On April 15, 2019, the U.S. House Committee on Oversight and Reform issued a subpoena to President Donald Trump's (R) accounting firm, Mazars USA, LLP ("Mazars"). The subpoena requested financial documents from the president in his individual capacity and from his companies with a deadline to comply of April 29, 2019.[7]

    Before April 29, President Trump and his business entities ("the plaintiffs") filed a lawsuit in the United States District Court for the District of Columbia, asking the court to issue a declaratory judgment and a permanent injunction against the subpoena. The district court denied the president's claims, granting summary judgment to the Oversight Committee.

    The plaintiffs appealed to the United States Court of Appeals for the District of Columbia Circuit, which affirmed the district court's decision.

    Trump v. Deutsche Bank AG

    On April 11, 2019, the U.S. House of Representatives Committee on Financial Services and the Permanent Select Committee on Intelligence issued subpoenas asking Deutsche Bank to provide financial records from President Donald Trump (R) in his individual capacity, his family members, and affiliated groups ("the plaintiffs"). The Financial Services Committee issued a similar subpoena to Capital One Financial Corporation.[8]

    Below is a brief timeline of the litigation in Trump v. Deutsche Bank AG:

    • May 3, 2019: The plaintiffs asked the court for a preliminary injunction, which the court denied.
    • December 3, 2019: The 2nd Circuit affirmed the district court's ruling.[8]

    Questions presented

    The petitioner presented the following questions to the court:

    Questions presented:
    • Whether the U.S. House Oversight and Reform Committee, Financial Services Committee, and Intelligence Committee have the "constitutional and statutory authority to issue" subpoenas to President Trump's accountant and to the president's creditors "demanding private financial records belonging to the president."[5][6]

    Outcome

    In a 7-2 opinion, the court vacated the judgment of the D.C. Circuit, holding the lower courts (the D.C. Circuit and the 2nd Circuit) did not adequately consider whether congressional subpoenas requesting information from the president raise separation of powers concerns.[3]

    Chief Justice John Roberts delivered the opinion of the court, in which Justices Ruth Bader Ginsburg, Stephen Breyer, Sonia Sotomayor, Elena Kagan, Neil Gorsuch, and Brett Kavanaugh, joined. Justices Clarence Thomas and Samuel Alito each filed dissenting opinions.

    Opinion

    In his opinion, Chief Justice Roberts emphasized the historic nature of the decision. He wrote, "We have never addressed a congressional subpoena for the President's information." The court held that Congress' investigative power was limited and must serve "a valid legislative purpose."[3]

    The chief justice wrote the standards offered by the president in oral argument would impede Congress from carrying out its responsibilities. On the other hand, the chief justice held the U.S. House's arguments would aggravate the separation of powers by giving Congress unlimited power to subpoena the president. He specified four standards for courts in assessing future lawsuits over congressional subpoenas of presidential information.[3]

    In his opinion, the chief justice wrote:

    “ The question presented is whether the subpoenas exceed the authority of the House under the Constitution. ... Congressional demands for the President’s information have been resolved by the political branches without involving this Court. ... Congress and the President maintained this tradition of negotiation and compromise—without the involvement of this Court—until the present dispute. Indeed, from President Washington until now, we have never considered a dispute over a congressional subpoena for the President’s records. And, according to the parties, the appellate courts have addressed such a subpoena only once, when a Senate committee subpoenaed President Nixon during the Watergate scandal. See infra, at 13 (discussing Senate Select Committee on Presidential Campaign Activities v. Nixon, 498 F. 2d 725 (CADC 1974) (en banc)). In that case, the court refused to enforce the subpoena, and the Senate did not seek review by this Court.


    This dispute therefore represents a significant departure from historical practice. Although the parties agree that this particular controversy is justiciable, we recognize that it is the first of its kind to reach this Court; that disputes of this sort can raise important issues concerning relations between the branches; that related disputes involving congressional efforts to seek official Executive Branch information recur on a regular basis, including in the context of deeply partisan controversy; and that Congress and the Executive have nonetheless managed for over two centuries to resolve such disputes among themselves without the benefit of guidance from us. ...

    The standards proposed by the President and the Solicitor General—if applied outside the context of privileged information—would risk seriously impeding Congress in carrying out its responsibilities. ... Such a categorical approach would represent a significant departure from the longstanding way of doing business between the branches, giving short shrift to Congress’s important interests in conducting inquiries to obtain the information it needs to legislate effectively. ... Because the President’s approach does not take adequate account of these significant congressional interests, we do not adopt it.

    The House’s approach fails to take adequate account of the significant separation of powers issues raised by congressional subpoenas for the President’s information. ... Far from accounting for separation of powers concerns, the House’s approach aggravates them by leaving essentially no limits on the congressional power to subpoena the President’s personal records. ... The House and the courts below suggest that these separation of powers concerns are not fully implicated by the particular subpoenas here, but we disagree. ... In addition, separation of powers concerns are no less palpable here simply because the subpoenas were issued to third parties. Congressional demands for the President’s information present an interbranch conflict no matter where the information is held.[9]

    		”
    —Chief Justice Roberts[3]

    Dissenting opinion

    Justice Thomas

    Justice Thomas filed a dissenting opinion in which he argued that Congress does not have the power to issue legislative subpoenas for private, nonofficial documents. In his opinion, Congress should use the power of impeachment if it wants to obtain these documents.[3]

    Justice Thomas wrote:

    “ Congress’ legislative powers do not authorize it to engage in a nationwide inquisition with whatever resources it chooses to appropriate for itself. The majority’s solution—a nonexhaustive four-factor test of uncertain origin—is better than nothing. But the power that Congress seeks to exercise here has even less basis in the Constitution than the majority supposes. I would reverse in full because the power to subpoena private, nonofficial documents is not a necessary implication of Congress’ legislative powers. If Congress wishes to obtain these documents, it should proceed through the impeachment power. Accordingly, I respectfully dissent.[9] ”
    —Justice Thomas[3]

    Justice Alito

    Justice Alito dissented on the grounds that the terms of the majority's remand were inadequate.[3]

    Justice Alito wrote:

    “ Courts must be very sensitive to separation of powers issues when they are asked to approve the enforcement of such subpoenas. ... I agree that the lower courts erred and that these cases must be remanded, but I do not think that the considerations outlined by the Court can be properly satisfied unless the House is required to show more than it has put forward to date. ... Because I find the terms of the Court’s remand inadequate, I must respectfully dissent.[9] ”
    —Justice Alito[3]

    Text of the opinion

    Read the full opinion here.

    Oral argument

    Audio

    Audio of oral argument:[10]



    Transcript

    See also

    External links

    Footnotes

    1. ↑ Trump v. Deutsche Bank AG came on a writ of certiorari to the United States Court of Appeals for the 2nd Circuit. The docket number is 19-760.
    2. ↑ SCOTUSblog, "Trump v. Deutsche Bank AG," accessed December 17, 2019
    3. ↑ 3.0 3.1 3.2 3.3 3.4 3.5 3.6 3.7 3.8 3.9 Supreme Court of the United States, Trump v. Mazars USA, decided July 9, 2020
    4. ↑ U.S. Supreme Court, "Press release from March 16, 2020," accessed March 16, 2020
    5. ↑ 5.0 5.1 SCOTUSblog, "Trump v. Mazars USA, LLP," accessed December 17, 2019
    6. ↑ 6.0 6.1 SCOTUSblog, "Trump v. Deutsche Bank AG," accessed December 17, 2019
    7. ↑ United States Court of Appeals for the District of Columbia Circuit, Trump v. Mazars US, LLP, decided October 11, 2019
    8. ↑ 8.0 8.1 United States Court of Appeals for the 2nd Circuit, Trump v. Deutsche Bank, decided December 3, 2019
    9. ↑ 9.0 9.1 9.2 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
    10. ↑ Supreme Court of the United States, "Oral Argument - Audio," accessed May 18, 2020
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