520 U.S. 681, 117 S. Ct. 1636, 137 L. Ed. 2d 945 (1997)
In May 1994 Paula Corbin Jones, a California resident who had worked at the Arkansas Industrial Development Commission, filed suit in the United States District Court for the Eastern District of Arkansas against William Jefferson Clinton, then President of the United States, and Danny Ferguson, a former Arkansas State Police officer.1 The complaint alleged that on May 8, 1991, while Clinton was Governor of Arkansas and attending an official conference at the Excelsior Hotel in Little Rock, Ferguson persuaded Jones to leave the registration desk and visit Clinton in a business suite where he made unwanted sexual advances that she rejected.2
Jones further alleged that after she refused the advances her superiors at the Commission treated her in a hostile and rude manner and changed her duties in retaliation.3 After Clinton became President, Ferguson made defamatory statements to a reporter implying she had accepted the advances, while Clinton's authorized spokespersons publicly branded her a liar by denying the incident.4
The four-count complaint asserted federal claims under 42 U.S.C. §§ 1983 and 1985 plus state-law claims for intentional infliction of emotional distress and defamation, seeking $75,000 in actual damages and $100,000 in punitive damages.5 Jurisdiction was predicated on federal-question and diversity grounds.6 With the exception of the defamation count, the alleged misconduct occurred before Clinton took office and was unrelated to any official presidential duties.7
Clinton promptly advised the District Court that he intended to file a motion to dismiss on grounds of Presidential immunity.8 He requested the court to defer all other pleadings and motions until after the immunity issue was resolved.9 Petitioner thereupon filed a motion to dismiss without prejudice and to toll any statutes of limitation until he is no longer President.10 The District Court denied the motion to dismiss, allowed discovery to proceed, but stayed the trial until the end of the presidency.11 Both parties appealed.12
A divided panel of the Court of Appeals for the Eighth Circuit affirmed the denial of dismissal on immunity grounds but reversed the stay of trial, holding that the District Court had abused its discretion.13 The Supreme Court granted certiorari.14
Whether a sitting President is entitled to absolute immunity from civil damages liability for actions taken before he entered office?15
A sitting President is not entitled to absolute immunity from civil damages liability for actions taken before he entered office.16 The separation-of-powers doctrine does not require it.17 Historical practice confirms no such immunity exists.18 The rationale of Nixon v. Fitzgerald applies only to official acts within the outer perimeter of presidential responsibility.19
No. The established facts demonstrate that Paula Corbin Jones filed her complaint in May 1994 alleging that in May 1991, while William Jefferson Clinton was Governor of Arkansas, he made unwanted sexual advances at the Excelsior Hotel in Little Rock and that her superiors later retaliated against her for rejecting those advances; those events occurred before Clinton took office and bore no relation to any official presidential duties.20 The District Court denied dismissal on immunity grounds, the Eighth Circuit affirmed that denial, and the Supreme Court granted certiorari to resolve the immunity question.21 Because the conduct at issue was unofficial and pre-presidential, the separation-of-powers concerns that justified absolute immunity in Nixon v. Fitzgerald are absent here.22
A sitting President is not entitled to absolute immunity from civil damages liability for actions taken before he entered office.
Related opinions on this issue
Justice Breyer concurs in the judgment that no automatic absolute immunity exists for pre-office conduct.23 He agrees that the Constitution does not automatically grant the President an immunity from civil lawsuits based upon his private conduct.24 Breyer emphasizes that the Constitution contains a principle based on Article II's vesting of the entire executive power in a single individual.25
That principle forbids a federal judge in an ordinary civil damages action to interfere with the President's discharge of his public duties.26 Once the President sets forth and explains a conflict between judicial proceeding and public duties, the matter changes.27 A court may schedule a trial only within the constraints of that constitutional principle.28
Breyer would place the burden on the President to explain the conflict and establish its need rather than grant categorical immunity.29
Justice Scalia concurs in the judgment allowing the suit to proceed because the alleged conduct occurred before Clinton became President.30 He maintains that the majority's separation-of-powers analysis is flawed.31 The separation of powers does require that the President be accorded absolute immunity from civil suits for damages arising out of his official conduct.32
Such suits would inevitably interfere with the functioning of the Executive Branch.33 They would divert the President's attention from his official duties.34 Because this case involves only unofficial pre-office acts, Scalia agrees the litigation may continue.35
Whether a district court abuses its discretion by staying trial of a private civil damages action against a sitting President until after his term expires?36
A district court abuses its discretion by staying trial of a private civil damages action against a sitting President until after his term expires when the stay is categorical, fails to account for the plaintiff's interest in timely adjudication, and rests on an insufficient record showing of interference with official duties.37
Yes. The established facts show that the District Court stayed the trial until the end of Clinton's presidency while permitting discovery to proceed, after finding that the public interest in avoiding litigation that might hamper the President outweighed any demonstrated need for an immediate trial, yet the record contained no specific evidence that a post-discovery trial would impair presidential functions.38 The Eighth Circuit reversed that stay as the functional equivalent of temporary immunity.39 The Supreme Court held the stay an abuse of discretion because it took no account of Jones's interest in prompt resolution, increased the risk of prejudice from lost evidence, and was premature given the absence of any record demonstrating impairment to executive functions, as judicial case management sensitive to the President's schedule can accommodate burdens without a categorical postponement.40
A district court abuses its discretion by staying trial of a private civil damages action against a sitting President until after his term expires.41
Related opinions on this issue
Justice Breyer agrees that the District Court's categorical stay was premature and that no automatic temporary immunity applies.42 He explains that the Constitution permits judges to schedule civil trials to avoid significant interference with a President's public duties once the President explains the conflict between the proceeding and his official responsibilities.43 Breyer stresses that the President must bear the burden of establishing need rather than receiving an automatic deferral.44
He would require the President to provide the District Court with a reasoned explanation of why postponement is needed before any scheduling order that could impair executive functions may issue.45 This approach diverges from the majority by highlighting the unique structural demands Article II places on a single individual who cannot delegate ultimate responsibility for the Executive Branch.46