Trump v. Mazars USA, LLP

Facts of the Case

In April 2019, three committees of the U. S. House of Representatives issued four subpoenas seeking information about the finances of President Donald J. Trump, his children, and affiliated businesses. Although each of the committees sought overlapping sets of financial documents, each supplied different justifications for the requests, explaining that the information would help guide legislative reform in areas ranging from money laundering and terrorism to foreign involvement in U. S. elections. Petitioners—the President in his personal capacity, along with his children and affiliated businesses—contested the subpoena issued by the Oversight Committee in the District Court for the District of Columbia and the subpoenas issued by the Financial Services and Intelligence Committees in the Southern District of New York. In both cases, petitioners contended that the subpoenas lacked a legitimate legislative purpose and violated the separation of powers. The respective district courts held that the subpoenas served a valid legislative purpose because the requested information was relevant to reforming financial disclosure requirements for Presidents and presidential candidates.

Question

Does the Constitution prohibit subpoenas issued to Donald Trump’s accounting firm requiring it to provide non-privileged financial records relating to Trump (as a private citizen) and some of his businesses?

CONCLUSION

The courts below did not take adequate account of the significant separation of powers concerns implicated by congressional subpoenas for the President’s information. Chief Justice John Roberts authored the 7-2 majority opinion of the Court.The Court first acknowledged that this dispute between Congress and the Executive is the first of its kind to reach the Court and that the Court does not take lightly its responsibility to resolve the issue in a manner that ensures “it does not needlessly disturb ‘the compromises and working arrangements’ reached by those branches. Each house of Congress has “indispensable” power “to secure needed information” in order to legislate, including the power to issue a congressional subpoena, provided that the subpoena is “related to, and in furtherance of, a legitimate task of the Congress.” However, the issuance of a congressional subpoena upon the sitting President raises important separation-of-powers concerns. The standard advocated by the President—a “demonstrated, specific need”—is too stringent. At the same time, the standard advocated by the House—a “valid legislative purpose”—does not adequately safeguard the President from an overzealous and perhaps politically motivated Congress.Rather than adopt either party’s approach, the Court proposed a balancing test that considers four factors. First, courts should carefully assess whether the asserted legislative purpose requires involving the President and his papers, or whether the information is available elsewhere. Second, courts should consider whether the subpoena is no broader than reasonably necessary in scope so as to still serve Congress’s legislative purpose. Third, courts should evaluate the evidence Congress has offered to “establish that a subpoena advances a valid legislative purpose”—the more “detailed and substantial,” the better. Finally, courts should assess what burdens a subpoena imposes on the President.Justice Clarence Thomas authored a dissenting opinion, in which he argued that Congress can never issue a legislative subpoena for private, unofficial documents.Justice Samuel Alito authored a dissenting opinion, in which he argued that even accepting the balancing test adopted by the majority, the House subpoenas should fail without a greater showing from the House as to each of the four considerations outlined by the majority.

Case Information

  • Citation: 591 US _ (2020)
  • Granted: Dec 13, 2019
  • Argued: May 12, 2020
  • Decided Jul 9, 2020