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Impeachable Offenses?

~ The Use & Abuse of Impeachment in the 21st Century

Impeachable Offenses?

Author Archives: impeachableoffenses

Mueller (supposedly) said Trump is not a “target” of his investigation — what does that mean?

04 Wednesday Apr 2018

Posted by impeachableoffenses in Uncategorized

≈ 3 Comments

Tags

grand jury target, Mueller, Robert Mueller, subject, target

By Frank Bowman

The Washington Post reports that Robert Mueller’s team has told Trump representatives that Mr. Trump continues to be under investigation, but is not now a “target” of the Mueller grand jury probe.  The Post article contains a good deal of commentary about what this means, most of which is broadly correct.  However, I think the Post misses several important nuances.

If Mueller’s people said Mr. Trump continues to be investigated (which in DOJ terminology makes him a “subject”), but that he’s not now a “target,” that allows two conclusions, one positive, one negative:

First, if Trump is still under investigation — is still a “subject” — Mueller has not exonerated Trump from criminal liability. Or putting it another way, the “subject” designation suggests Mueller has found enough evidence of Trump’s possible involvement in crime that he thinks it’s worthwhile to continue to investigate Trump.

Second, the “not a target” designation doesn’t convey much of real substance concerning Mueller’s assessment of the current evidence against Trump. The Washington Post summary of the meaning of “target” is incomplete. The article says, “A target is a person for which there is substantial evidence linking him or her to a crime.” But that’s not the whole definition in the United States Attorneys Manual (9-11.151), which reads: “A ‘target’ is a person as to whom the prosecutor or the grand jury has substantial evidence linking him or her to the commission of a crime and who, in the judgment of the prosecutor, is a putative defendant.”

If Mueller really said Trump is not a “target,” all he may be saying is that, while there is substantial evidence linking him to a crime, DOJ policy precludes making him an actual indicted “defendant.” For an explanation of this policy, see this earlier post. What’s more, as several commenters in the WP article note, a subject can change to a target in the blink of an eye.

Were I one of Trump’s lawyers, I would be more alarmed than comforted by what Mueller supposedly said.

UPDATE: Jeremy Stahl over at Slate was kind enough to quote me about this point in a longer story on the Washington Post report.

 

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The Strange Case of Jefferson Beauregard Sessions

30 Friday Mar 2018

Posted by impeachableoffenses in Uncategorized

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By Frank Bowman

The endless fever dream of the Trump era has no stranger aspect than our for-now-at-least Attorney General Jefferson Beauregard Sessions.  On the one hand, from the point of criminal justice policy, he is in the running as objectively the worst Attorney General of the last half-century.  It’s not merely that he is conservative on criminal justice issues.  Any Republican Attorney General in a post-Obama Republican presidency would surely have retrenched somewhat on some of Obama’s liberalizing initiatives.

The truly distressing aspect of Sessions’ tenure is that he combines two mutually reinforcing tendencies.  The first is Sessions’ own attitudes to crime.  His views on crime and punishment were, it seems, formed in the 1980s when a core tenet of social conservatism was that the only answer to crime in general, and drug crime in particular, was punishment in the form of ever longer terms of imprisonment.  The result — mass incarceration at levels unparalleled in what used to be called the free world — has been so unpalatable, and its human and financial costs so obviously disproportionate to its benefits, that even most conservatives have recoiled and actively begun searching for more humane and cost-effective means of addressing crime. Organizations like “Right on Crime” have been proposing conservative alternatives to mass incarceration, and have had some success implementing them in the states.  Such efforts are even endorsed by liberal boogiemen like Newt Gingrich and the Koch brothers.

Indeed, criminal justice reform is one of the few tough policy areas on which there is a large degree of agreement between thoughtful conservatives, moderates, and liberals.  And yet we have in Jeff Sessions one of the last diehard paleoconservative tough-on-crime guys.  He and a handful of like-minded cavemen – a pejorative term I do not use lightly — notably including Sen. Tom Cotton, seem impervious to either moral or evidence-based arguments against thoughtless “toughness.”  By sticking together and relying on Sen. McConnell’s refusal to allow consideration of any measure without near-universal Republican support, they prevented the passage of even a modest sentencing reform bill in the last congress.  In doing so, they thwarted the wishes of the majority of their Republican colleagues, not to speak of Democrats.  Sessions’ opposition to a new effort at such legislation is again proving an impediment and has stirred the wrath even of so reliable a pillar of the Republican right as Judiciary Committee chairman Charles Grassley.

Worse, Sessions’ personal rigidity is meshing with the near-official Trump Administration policy of voiding any Obama policy initiative, regardless of merit.  Sessions is reversing all the Obama-era ameliorations of prosecution policy on drug and other cases, and threatening to upend the federal-state ceasefire regarding differing treatment of marijuana.  It also appears that the Sessions Justice Department has effectively gutted Obama-era federal prison education initiatives.  And the beat goes on.

And yet, as dreadful as Sessions is on substance, he remains, perversely, the single flimsy barrier against removal of Robert Mueller and the shutdown of the investigation Mueller heads.  Sessions’ one possible redeeming feature is his respect for the Justice Department as an institution.  He has compromised the Department on more than one occasion, most recently in his firing of former FBI Deputy Director McCabe.  But he seems to be clinging to some shreds of personal and institutional self-respect.  Just his week, Sessions appears to have done another good thing, in deflecting the call by House Republicans for a second special prosecutor to look into Hillary Clinton, the dossier, and who knows what else by instead referring the investigation of all such matters to the DOJ Inspector General and to a general review by, John W. Huber, the U.S. Attorney for the District of Utah.

The assignment of Huber to be something more than a regular U.S. Attorney and something less than a “special counsel” is an interesting move.  Presumably, Sessions hopes that Huber’s work will check the cacaphony from House Republicans without unleashing a new special counsel operating at cross-purposes with Mueller.  Likewise, it may be that Sessions hopes that, if Huber finds no reason for more extensive investigation, that will carry weight with Orin Hatch, who himself carries considerable heft in paleoconservative circles.

I have had hard things to say of Mr. Sessions before, and doubtless will again.  But at least as regards Mueller and related matters, he is — tenuously — clinging to his reputation as a Justice Department institutionalist.    Whether that will be enough in the end to redeem him, and the rest of us, remains to be seen.

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The McCabe Firing & Jeff Sessions

17 Saturday Mar 2018

Posted by impeachableoffenses in Uncategorized

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Andrew McCabe, Jeff Sessions, McCabe

By Frank Bowman

Attorney General Jeff Sessions fired Former Deputy Director of the FBI Andrew McCabe late last night, barely a day before his pension would have vested.  This event tells us more about Mr. Sessions than Mr. McCabe.  And to me, whatever McCabe’s transgressions, the man who is leaving the Justice Department looks rather better than the man who, for now, continues to head it.

Let’s begin with a few obvious points:

  • The official reason for McCabe’s firing was a conclusion by the Justice Department’s Inspector General that McCabe had been less than candid about the circumstances under which he authorized the release of information to reporters from the Wall Street Journal about aspects of the Clinton investigation.  I am obviously not privy to the particulars of that IG report; however, I have some acquaintance with Michael Horowitz, DOJ’s Inspector General.  I know him as an excellent lawyer, an honest man, and a nonpartisan straight arrow.  He is an Obama appointee and certainly no Trump flunky.  Hence, it seems very likely that McCabe did cross some professional line.
  • That said, the decision about what penalty to impose for McCabe’s transgression did not rest with Michael Horowitz.  It has been reported that the FBI’s Office of Professional Responsibility recommended that McCabe be fired. If true, that lends further credence to the notion that McCabe’s transgression was fairly serious, or at least that reasonable professionals could view it as being so.
  • Nonetheless, the timing of the firing, after the business day on a Friday, and mere hours before McCabe qualified for a pension earned for more than 20 years of FBI service — which excepting whatever lapse of judgment got him fired, was by all accounts exemplary — can only be seen as small, vindictive, and mean spirited.  Which is to say that one would see Mr. Trump’s signature in the affair even if that master of pettiness and bile had not publicly complained that McCabe might be allowed to retire with his pension.
  • Jeff Sessions made this call.  He could have followed the advice of the FBI’s professional responsibility office and separated McCabe from government service, but a person of any class would either have allowed McCabe to retire or at worst ordered his termination sometime in the coming weeks.  Instead, he cravenly chose to do the bidding of his dark master and snatch pension benefits from a career public servant.

The result is that Sessions looks far worse than McCabe.  He is exposed as a hypocrite, a weakling, and a fool.

Hypocrite: The idea that Donald Trump and Jeff Sessions combined to fire a career FBI agent for “lack of candor” reeks to heaven of hypocrisy.  Mr. Trump’s incorrigible dishonesty is by now so universally recognized that it no longer elicits much more than weary groans.  He lies to everyone, including foreign heads of state, and then brags about the lies.  But Sessions’ slate is hardly clean.  This is a man who has made repeated misstatements to the Senate about his Russian contacts. When called to account by former colleagues, he feigned outrage at the challenge to his honor, but the display rendered his strategic misrememberings no less incredible.  That this precious pair of dissemblers have the gall to discipline anyone else for lack of candor is very hard to stomach.

Weakling: The decision to fire McCabe when and how he was fired was a transparent bow to the wishes of Mr. Trump.  While the manner and timing of McCabe’s release may not have violated DOJ personnel rules (although that is a contestable point which McCabe may raise in court), it was, so far as I know, unprecedented.  I know of no case where a president publicly campaigned for the firing, humiliation, and financial punishment of a third-tier career public servant.  Still less am I aware of any case where a cabinet officer was so spineless as to acquiesce in such executive bullying.  To give him his due, Jeff Sessions has occasionally shown signs of  independence and a desire to protect the institutional integrity of the Justice Department, most recently his staged public dinner with Deputy AG Rod Rosenstein and Solicitor General Noel Francisco.  But the McCabe firing demonstrates, at least to my mind, Sessions’ essential hollowness.  Trump is a bully.  Sessions, who for all his well-documented flaws has led a life of far greater accomplishment than our erstwhile president, nonetheless lacks the moral core that moves persons of decency to stand up to bullies.

Fool: Perhaps the most remarkable thing about Sessions’ toadying to Trump by humiliating McCabe is not the meanness or the cowardice, but that, even as part of a selfish calculus of self-preservation, it surely will do Sessions no good.  Trump wants him out because, so long as Sessions is both AG and recused from overseeing Robert Mueller’s investigation, Trump can’t stop or cripple the investigation.  Therefore, Sessions is a dead man walking.  The only questions are when the axe will fall and how Sessions will be remembered once he’s gone.  Sessions is mad to think that the mad king will be sufficiently mollified by the manner of McCabe’s departure to preserve Sessions in office even a single day longer than would be the case had Sessions exhibited some magnanimity and grace.  And by yielding to the vicious whims of the plutocrat in the White House to gratuitously strike at the retirement security of a middle class career FBI agent, Sessions will earn the deserved contempt of all those who have ever been in federal service.

There is, or at least I hope there will prove to be, a sad moral in the tale of Jeff Sessions.  He hitched his wagon to the rising star of a man manifestly unfit for the high office of the presidency.  And he was rewarded beyond any reasonable expectation with his dream job — Attorney General, head of an agency that I think Sessions genuinely reveres.  But what Sessions is likely to find in the end is that his betrayal of principle in the pursuit of ambition will yield only ashes.  His lies to congress in the service of an unworthy boss have cost him the respect of many of his former senatorial colleagues.  His truckling to Trump, including the cruelty to McCabe, will cost him the respect he craves from the professionals of the Justice Department.

Jeff Sessions’ story is not yet ended.  He may yet redeem himself by some act of unexpected political courage.  But at the moment, he risks relegation to the small, sad club of ignominiously failed Attorneys General.  And his name will be spoken, when it is remembered at all, in company with Alberto Gonzales and John Mitchell, men too warped and small for the great office they ultimately sullied.

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Impeachment in the States: Missouri Governor Edition, Part 4 (Erratum)

13 Tuesday Mar 2018

Posted by impeachableoffenses in Uncategorized

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Greitens, Greitens impeachment, Greitens sex scandal, Missouri constitution, RSMO 565.021

By Frank Bowman

If one is going to offer oneself as an “expert” on stuff to the press, one has to be ready for the inevitable humbling moments when one’s off-the-cuff opinions prove wrong.  The other day, the Columbia Missourian interviewed me about impeachment procedure in Missouri, and I suggested that, if Governor Greitens were convicted of a felony in St. Louis,  then RSMo 561.021, which disqualifies any elected official from office if convicted of a felony, would require Gov. Greitens’ immediate removal from office without the necessity of an impeachment proceeding.

A better-informed reader of the Missourian wrote in to say, politely, that I was talking through my hat.  Rather, the reader pointed out, several Missouri cases have held that, in  the case of statewide offices which are created by the constitution and for which the constitutionally prescribed means of removal is impeachment, the legislature may not prescribe some other removal procedure.  For those interested, the main cases are State Ex Inf. Attorney-General v. Brunk, 34 S.W.2d 94 (Mo. 1930) and State ex Inf. Nixon v. Moriarty, 893 S.W.2d 806 (1995).

Had I been thinking more clearly before succumbing to the pleasures of bloviation, I would have realized that the federal constitutional principle that permits removal of “the President, Vice President and all civil officers” only upon impeachment should apply equally in the states.  Missouri differs from the federal situation in that Missouri has a statute that purports to disqualify all elected officials who suffer a felony conviction.  But the principle that has forestalled Congress from attempting to pass felony disqualification laws or other removal shortcuts for federal officeholders is the same in both the federal and state situation. The basic idea is that, if the fundamental law of a nation or state provides an exclusive means of removing the holders of major offices, then the legislature cannot create a shortcut to that end through enactment of a mere statute.

So, with thanks to the Missourian‘s astute reader, I stand corrected.  If Governor Greitens is to be removed, it will be through impeachment, even if he is first convicted of a felony in St. Louis.

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A sound, if politically improbable, way to protect Mueller

19 Monday Feb 2018

Posted by impeachableoffenses in Uncategorized

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Bork, Cox, Jaworski, Katyal, Mueller, sessions, Starr

By Frank Bowman

Readers of this site who don’t also take the New York Times should consider reading a Times Op-Ed by Neal Katyal and Ken Starr, linked here. It relates a little-remembered coda to Robert Bork’s decision to acquiesce in Richard Nixon’s order to fire Watergate Special Prosecutor Archibald Cox.  Bork, to his immense credit, appointed a solid replacement for Cox in Leon Jaworski, and promulgated an internal DOJ regulation making it extremely difficult for the president to fire the new guy.  That regulation has long since lapsed, to be replaced by the less protective one under which Robert Mueller operates.  Nonetheless, something like it could be implemented without congressional action.

The key questions, however, are whether Attorney General Jeff Sessions would countenance such a regulation, and, even more centrally, whether Mr. Trump would squelch the idea.  The likelihood that either or both would allow it seems very small indeed. Still, unlike a lot of stuff that appears in the national press about the Mueller investigation, this is a reasonable proposal from two people with long experience at DOJ.

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Mueller indicts some Russians … and the noose tightens

17 Saturday Feb 2018

Posted by impeachableoffenses in Uncategorized

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Tags

impeachable offense, indictment, Indictment of Russians, Marco Rubio, Mueller, national security, Robert Mueller, Rod Rosenstein, Steele dossier, Ted Cruz

By Frank Bowman

Yesterday, Deputy Attorney General Rod Rosenstein announced that Robert Mueller’s team had obtained an indictment against thirteen Russian persons and three Russian firms charging them with a variety of crimes committed in the course of an integrated scheme by the Russian government to swing the 2016 presidential election to Mr. Trump.  I’m not going to discuss the details of the indictment here; they are well-covered elsewhere, including in the New York Times and Slate, and anyone who reads this blog will surely  have devoured the particulars.  For now, I’ll make only a couple of points:

  • This is an important development. It puts into the public realm the particulars of the long-reported conclusions of every U.S. intelligence agency that Russia meddled in the 2016 election on Trump’s behalf, and stamps those conclusions with the imprimatur of a federal grand jury.  Mr. Trump, who rarely lets facts constrain his private musings or public utterances, may keep doubting Russian interference.  But except in the more fever-haunted corners of the right-wing media, the fact of Russian meddling on Trump’s behalf now becomes impossible to deny.
  • Ardent Trump opponents will doubtless be disappointed that the indictment does not charge any affiliates of the Trump campaign with knowingly aiding Russians in their nefarious activities.  It does say that Trump campaign affiliates cooperated with Russians in various ways, but is careful to describe such persons as “unwitting individuals affiliated with the Trump campaign.” The key point here, as numerous commentators have observed, is that the particular activities specified in the indictment are of a sort that required concealing Russian involvement.
  • However, this indictment does not address the events most likely to have included knowing collusion with Russians by Trumpists, most notably the multiple efforts by high-level Trump campaign operatives, including Donald Trump, Jr., to obtain “dirt” on Hillary Clinton from Russians; Donald Trump Sr.’s public encouragement of Russian theft of Clinton e-mails; possible contacts between Trump operatives and Wikileaks (which in turn probably got dirt on Secretary Clinton from the Russians); etc.  And this indictment has nothing to say about the possibility that Russia may have secured compromising information about Mr. Trump, thus giving them the sort of leverage over him that would help explain their enthusiasm for his candidacy.
  • Accordingly, the claim by Trump spokesmen that this indictment clears Mr. Trump of “collusion” is nonsense.  All one can say is that this indictment does not address that issue.  Whether subsequent indictments will do so is an entirely different question.

The more intelligent among Mr. Trump’s defenders should be very worried by this indictment.  For these reasons:

  • By laying out in surgical detail a calculated foreign assault on American democracy, it shreds the notion that the Mueller investigation is a partisan “witch hunt.”  In light of the facts laid out in the indictment, the Trumpist effort to blame the whole investigation on a convoluted conspiracy between Democrats and Russians to manufacture the Christopher Steele dossier becomes facially absurd.  That’s not to say Trump allies won’t keep flogging Mr. Steele.  They surely will. But to anyone with even a hint of objectivity, the idea that the Mueller investigation is all about a “dodgy dossier” is now untenable.
  • The indictment makes plain that the Russians were not merely intervening against Hillary Clinton, but were working for Mr. Trump, uniquely among Republican candidates. Among the indictment’s nice details is the fact that the Russians campaign  disparaged not only Secretary Clinton, but also Ted Cruz and Marco Rubio.  This fact gives rise to the obvious question — why Trump?  There are two possible answers, neither of them happy for Trump fans.  Either the Russians simply thought of Trump as the chaos candidate, a man whose ascendance would disrupt American democracy (a sadly prescient notion), or in a more sinister vein, they really do have something “on” Trump in the sense of possessing information about either his personal or business affairs that would render him amenable to Russian pressure.
  • This indictment makes it materially harder for Mr. Trump to fire Mueller and stop his investigation.  To fire Mueller now would halt an investigation into a demonstrated national security threat, something all but the most degraded congressional Republicans would find hard to swallow. Moreover, by choosing to personally announce the Mueller indictment, Deputy AG Rosenstein signaled that the Justice Department as an institution is standing behind Mueller’s work.  Rosenstein is saying, as plainly as if he put up a sign, “To get to Mueller, you have to take me out first.” What’s more, I read this as not merely a personal declaration, but as Rosenstein throwing down the gauntlet on behalf of career federal prosecutors unwilling to be cowed by the bluster of a president under suspicion.  This doesn’t mean Trump won’t go on a firing spree anyway.  But I think this indictment makes that less probable and makes the political cost of such a spasm much higher.
  • Which leads me to the last, and perhaps most critical point. Had Mr. Trump fired Mueller last week, he could (and would) have tried to excuse it as stepping in to stop a frivolous politically-motivated fraud. With this indictment, the Mueller investigation has irrefutably become a matter of protecting national security.  Should Mr. Trump shut the whole thing down now, that alone would, in my judgment constitute an impeachable offense and one that would resonate across party lines.  It would be bad enough for a president to fire a special counsel to protect his personal or political interests.  That would be impeachable behavior, to be sure, but Trump’s apologists could try to justify the firing as mere self-protection against the corrupt activities of evil Democrats and the nefarious “Deep State.”  But for Mr. Trump to shut Mueller down now would be to abrogate, openly and unapologetically, the president’s basic responsibility to protect the country and constitutional democracy itself from foreign enemies.  Even if the degraded specimens who now represent the Republican Party on the House Judiciary Committee were unwilling to move against Trump in such a case, a Democrat-controlled House would view the matter differently.  And I suspect, or at least hope, that a good number of honest Republicans would agree.

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No, the Grand Jury Can’t Proceed Without Mueller (or at least some federal prosecutor)

15 Thursday Feb 2018

Posted by impeachableoffenses in Uncategorized

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Bennett Gershman, David Yassky, grand jury, grand jury report, indictment, Robert Mueller, Special Counsel

By Frank Bowman

As regular readers of this site are well aware, I deeply disapprove of Mr. Trump, his shameless enablers, and all their works.  And I’m entirely in favor of employing the legitimate tools of both law and politics to oppose Mr. Trump and to expose his criminal or impeachable conduct, if any.

But, at least for me, that doesn’t mean anything goes. Indeed, because the fundamental sin of Trumpism,  from which all its other evils flow, is disregard of legal rules and norms, Trump critics have a special responsibility not to bend the law or misrepresent what it permits.  This being so, I have too regularly found myself in the role of starchy maiden aunt prudishly reproving fellow Trump critics when they trot out yet another implausible interpretation of the law or the mechanics of criminal practice.

Earlier this week, I got after Professor Larry Tribe and co-authors for suggesting that Congressman Devin Nunes committed obstruction of justice by releasing the infamous memo.  And sadly, I’m back at it today.

In the February 14 edition of Politico, law professors David Yassky and Bennett Gershman contended that, even if special counsel Robert Mueller and all his team were fired, somehow the grand jury empanelled to investigate the Trump-Russia connection could continue the investigation, and even produce an indictment. For a half-a-hundred reasons, some legal and some practical, this could not happen.  In my own piece on Politico today, linked here, I explain why.

I hope, in future, to spend more time on what Trump opponents can do, and less on what they can’t.

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Larry Tribe & Company Jump the Shark: Whatever Devin Nunes may be doing, it’s not obstruction of justice

12 Monday Feb 2018

Posted by impeachableoffenses in Uncategorized

≈ 3 Comments

By Frank Bowman

In this morning’s New York Times, eminent Harvard Law Professor Larry Tribe, joined by Norman Eisen, former ambassador and White House ethics adviser, and Caroline Fredrickson, president of the American Constitution Society, published an op-ed arguing that Congressman Devin Nunes may have committed the crime of obstruction of justice by coordinating with the White House to release the infamous MEMO that attacked the credibility of the infamous DOSSIER compiled by former British spy Christopher Steele.

I yield to no one in my contempt for Congressman Nunes’s ridiculous memo, which I characterized as “a tragicomic face-plant. Likewise, I am heartsick at the coordinated efforts by Republican congressmen to undercut the Russia investigation and undermine the Justice Department. Nonetheless, while the behavior of Nunes and his unsavory congressional cohorts is tragic and deeply un-American, it’s not the crime of obstruction of justice. And labeling it as such is a sad mistake.

As I have discussed at length elsewhere, obstruction can be prosecuted under a number of statutes, the most likely being  18 United States Code, Section 1503 and 18 United States Code, Section 1512. A violation of Section 1503 occurs if a defendant “corruptly … endeavors to influence, intimidate, or impede any … officer in or of any court of the United States, or … corruptly… influences, obstructs, or impedes, or endeavors to influence, obstruct, or impede, the due administration of justice.” The last phrase is the so-called “omnibus clause” and has been construed quite broadly by federal courts. A violation of 18 United States Code, Section 1512(c) occurs if a defendant: “corruptly … obstructs, influences, or impedes any official proceeding, or attempts to do so….”

The Tribe/Eisen/Fredrickson theory of obstruction runs thus: (1) “[T]he Nunes memo may be designed at least in part to provide the president an excuse for firing Deputy Attorney General Rod Rosenstein, the individual with supervisory authority over Mr. Mueller, the special counsel in charge of the [Trump-Russia] investigation.” (2)  The objective of this “scheme” is to “clear a path to install a Trump-friendly replacement who would either fire Mr. Mueller or otherwise defang the investigation.” (3) Therefore, Nunes has obstructed justice.

Note that, even as stated, the object of the purported “scheme” is completely speculative. Tribe and company write that the memo “may be designed at least in part” to provide Trump an excuse to fire Rosenstein and then Mueller. Maybe. But it’s equally plausible that the memo is designed, not to enable Mueller’s removal, but to pre-emptively discredit his findings in the mind of the public, thus providing a political benefit both to Trump and to the political party whose fortunes are increasingly tied to his. The latter objective is slimy in the last degree, but it’s not criminal.

Moreover, even if Nunes is “scheming” with the White House to clear the way for Mueller’s removal, that is not obstruction of justice unless Nunes has a “corrupt” purpose. Tribe and company acknowledge this point, but glide right past it, making no effort to explain what Nunes’ corrupt purpose was or with what evidence it might be proven.  For them, it seems to be enough that Nunes’ has acted “at least in part” with the aim of getting Mueller fired.

As much as Trump opponents may want to think otherwise, opposition to Mueller and his investigation is not, in itself, immoral or illegal.  It is perfectly possible to conclude that no such investigation should be occurring, or that, if it must occur, someone else ought to be running it.  I disagree on both points, and I think that people who entertain these views are either cynical partisans or gravely, if honestly, mistaken.  But I don’t imagine that disapproving of Bob Mueller’s work is “corrupt.”

To prove that Nunes acted “corruptly” one would have to show that he believed that a “natural and probable effect” of his memo would be the firing of Robert Mueller, and that he believed firing Mueller would stop or impede the investigation Mueller heads, and that he believed Mueller’s investigation is not a “witch hunt,” but a legitimate inquiry into matters deserving of federal law enforcement attention. Some might argue that, as a matter of law, it doesn’t matter what Nunes believes about the legitimacy of the Mueller inquiry.  Technically that might be so.  But pragmatically, it makes all the difference in the world.

Imagine that a rogue U.S. Attorney began investigating the ACLU and the NAACP based on specious claims that they were treasonous communist front organizations in league with North Korea. One would hardly think of charging a congressman with obstruction of justice if the committee he chaired were to provide the White House and the public with information undercutting the credibility of the overzealous U.S. Attorney in hopes of getting him fired.

Finally, as Tribe and company concede, congressmen are protected by the speech or debate clause of Article I, Section 6, from prosecution for activity integral to legislative or oversight responsibilities.  The authors strive mightily to distinguish Nunes’ activities from those covered by the constitution, but their efforts are ultimately strained and unconvincing. After all, the memo was issued, not by the White House or by Devin Nunes in his personal capacity, but by the Republican members of a congressional committee chaired by Congressman Nunes.

But the big point here is that, regardless of the technicalities, no sane federal prosecutor would seriously consider indicting a United States congressman on these facts. It just would not happen.  And one has to assume that, as intelligent and sophisticated lawyers, Professor Tribe, Mr. Eisen, and Ms. Fredrickson know that.

That being so, it is hard to see what is accomplished by publishing such stuff. Sure, it feeds the hopeful fantasies of the many Americans who understandably despise Mr. Trump and his enablers.  But it’s not real.  It’s sloppy result-driven legal analysis untethered to any appreciation of real-world behavior in the criminal justice system.  It lends undeserved credence to Alan Dershowitz’s constant refrain that Trump opponents want to criminalize ordinary politics. It feeds into the broader right-wing narrative that liberal lawyers are mere anti-Trump propagandists incapable of dispassionate analysis.

And so, to Professor Tribe and friends I would say this: Lord knows I sympathize with your distaste for Mr. Trump.  And I, too, would like nothing more than to see the man out of the office he daily disgraces. But please stop trying to shoehorn every deplorable act of this concededly deplorable crew into a criminal statute.  It diminishes not only your credibility, but that of other legal critics of Mr. Trump and his minions.

More importantly, the problem with Nunes’s clumsy machinations is not that they constitute a technical violation of a federal criminal statute, but that they amount to an open and notorious assault on the integrity of the entire legal and national security apparatus of the United States.  That’s a “political” problem, in the broad sense of the term employed by Alexander Hamilton when he spoke in Federalist 65 about the political character of impeachable offenses. It is a cardinal error to jam Trumpist assaults on the norms of republican government into ill-fitting technical legal categories.  To do so both diminishes the seriousness of the mortal challenge Trumpism presents to American democracy and affords Trumpists a cheap defense — if their outrageous behavior proves not technically criminal, they can proclaim it entirely acceptable.

In the end, the criminal justice system may play a supporting role in solving the Trump problem, but that problem will only finally be solved by political means — convincing a sufficiently abundant majority of the American people to repudiate Mr. Trump and his allies at the ballot box. Only in that way will Mr. Trump be denied a second term, and only in that way will a congress be elected in 2018 that takes impeachment seriously.

 

 

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Impeachment in the States: Missouri Governor Edition – Part 3 (The Picture)

10 Saturday Feb 2018

Posted by impeachableoffenses in Uncategorized

≈ 1 Comment

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Greitens impeachment, Greitens sex scandal, impeachment in the states, impeachment of governor, impeachment of Greitens, invasion of privacy, tampering with physical evidence

This site has previously discussed the Missouri law applicable to impeachment of governors and its application to the sex scandal swirling around Gov. Eric Greitens. We have previously noted that state officials are impeachable for virtually any misconduct violative of state law, including criminal misdemeanors.  We have observed that the offense Mr. Greitens seems most likely to have committed (if the publicly reported information proves accurate) is invasion of privacy, RSMo 565.252.

Mr. Greitens would be guilty of this crime if he took a picture, without the consent of the woman with whom he was having a sexual interlude, while she was fully or partially unclothed.  Mr. Greitens would be guilty of the more serious felony offense of tampering with physical evidence, RSMo 575.100, if he took such a picture and later, “Alter[ed], destroy[ed], suppresse[d] or conceal[ed the photo] with purpose to impair its verity, legibility or availability in any official proceeding or investigation.”

The question of whether such a picture was ever taken, and if so what happened to it, has become a running theme in Mr. Greitens’ interactions with his critics and with members of the press. Several days ago, for example, a reporter for the St. Louis Post Dispatch asked Mr. Greitens directly whether he had taken a photo of his former mistress.  Mr. Greitens declined to answer, claiming that he had answered questions about the matter before. However, Mr. Greitens has never denied taking such a picture, despite having had multiple opportunities to do so.  In his most extensive previous statement, Mr. Greitens said:

“This was a consensual relationship. There was no blackmail, there was no violence, there was no threat of violence, there was no threat of blackmail, there was no threat of using a photograph for blackmail. All of those things are false.”

Note that he denies “using a photograph for blackmail,” not taking a photograph in the first place.  It’s a curious circumlocution.  If no photograph was taken, why not say so plainly, and as Ephesians 6:14 puts it: “Stand firm then, with the belt of truth buckled around your waist, with the breastplate of righteousness in place”?

Indeed, even if one’s belt of truth had of late come unbuckled, it would make sense to deny that a photograph was ever taken … unless, of course, there really was a photograph and one feared that evidence of its existence might surface.

It may prove that Mr. Greitens was simply inartful in his original statements about this matter, and is now simply being unwisely stubborn in his refusal to amplify on an undoubtedly painful subject.  Still, if Mr. Greitens neither took nor destroyed an incriminating photograph, he ought to say so in plain terms and put the matter to rest.  So long as he evades these questions, a cloud of suspicion rather larger than a man’s hand will hang over his office and unnecessarily complicate the state’s affairs.

Frank Bowman

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AAG Rachel Brand Quits: Who’s Next?

10 Saturday Feb 2018

Posted by impeachableoffenses in Uncategorized

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Associate Attorney General, Noel Francisco, Rachel Brand, Robert Bork, Saturday Night Massacre, Solicitor General

By Frank Bowman

Associate Attorney General Rachel Brand, the number 3 official in the Justice Department, resigned today after barely nine months in office to take a position with Walmart. This matters because Ms. Brand would have been the next person in line if: (a) Mr. Trump ordered Deputy Attorney General Rod Rosenstein to fire Special Counsel Robert Mueller, and (b) Rosenstein either refused and resigned or refused and was fired.  With Rosenstein gone, Ms. Brand would face the same unpalatable choice.  It would seem she does not want to be this generation’s Robert Bork.

For those not up on their Watergate history, Mr. Bork was the Solicitor General at the time President Nixon ordered the firing of Watergate special prosecutor Archibald Cox.  Nixon ordered Attorney General Elliot Richardson to fire Cox. Richardson refused and resigned in protest. Nixon then gave the same order to Deputy Attorney General William Ruckelshaus, who also refused and resigned. Whereupon Nixon turned to Robert Bork, who fired Cox.

Although Bork was a brilliant lawyer and one of the leading intellectual lights of the budding conservative movement, he forever bore a Mark of Cain for the firing, particularly after it became clear that Nixon had indeed committed both crimes and impeachable offenses. When he was nominated for the Supreme Court by President Reagan, the nomination failed, partly because of fierce opposition to his criticism of many of the civil rights and criminal procedure precedents set by the Warren and Burger courts, but certainly also because of his role in the “Saturday Night Massacre.”

Ms. Brand’s departure raises several interesting questions:

First, who takes her place in the DOJ hierarchy?  Presumably someone will be named acting Associate Attorney General fairly quickly.  The AAG plays too large a role in administration of the Department for the job to remain vacant indefinitely.  One move the White House might try would be to appoint as acting AAG a Trump loyalist willing to do the dirty deed of immediately firing Mueller. Such a person would have to know that doing so would surely prevent confirmation into the job on a permanent basis, and if rational, would also realize that acting as Trump’s henchman would permanently ostracize him or her from the federal law enforcement community. I doubt there are many such creatures in the middle and upper reaches of the Justice Department.

There is also the possibility that Mr. Trump could insert a political hitman from the outside into the acting AAG position. That is highly unlikely, but not impossible.  Under the Federal Vacancies Reform Act of 1998, an acting replacement for a position requiring senate confirmation (which Associate Attorney General does) must either (1) already occupy an advice and consent position (i.e., a position for which he or she was nominated by the president and confirmed by the Senate), or (2) be an employee of the same agency for at least 90 days prior to appointment and have a salary equal to a GS-15 (the highest grade of ordinary civil service rank).  This means that an acting replacement for Ms. Brand from outside DOJ would already have to occupy a Senate-confirmed position in some other agency, or be inserted into the Department as a regular employee with the appropriate pay grade 90 days before becoming Acting AAG.

The first option expands the pool of possible acting replacements for Brand from Main Justice political appointees and confirmed U.S. Attorneys to anyone holding an advice and consent position anywhere in the government.  The second move would be awkward and transparently obvious, and would take three months to arrange.

Second, so long as the AAG slot remains empty, or the acting AAG refuses to fire Mueller, the next person in line is, once again, the Solicitor General, currently Noel Francisco. I know nothing whatever about Mr. Francisco, other than that he has a distinguished resume as an appellate practitioner.  It seems hard to imagine that he would relish becoming this generation’s Robert Bork.  The lessons of Watergate for a man in his position are pretty stark. But one never knows.

For a more detailed look at the line of succession after Solicitor General Francisco, see Professor Jed Shugerman’s blog.

The larger message of the Brand departure, and for that matter of the ongoing turmoil at the White House caused by the resignation of staff secretary Rob Porter (and a few hours ago speechwriter David Sorensen) over domestic abuse allegations, is that few quality people are willing to accept high office in the Trump Administration, and those of any integrity, or merely a sense of professional self-preservation, tend to leave fast.  One senses that both the reluctance to join the Trump parade and the disposition to leave it are increasing.

The problem for the country is that the federal government is increasingly either unstaffed at senior levels or in the hands of sycophants and second-raters. Sadly, many, perhaps most, of Mr. Trump’s loyal base either don’t know this or have been so indoctrinated by years of right-wing anti-government propaganda that they believe the accelerating deconstruction of the national government is a positive good.

In many ways, the denouement of the Mueller probe is the least of our worries….

 

 

 

 

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Frank O. Bowman, III


Curators' Distinguished Professor Emeritus
Floyd R. Gibson Missouri Endowed Prof of Law Emeritus
Univ of Missouri School of Law

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