Constitutional Law Case Brief - Clinton v. Jones (1997)

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Clinton v. Jones, 520 U.S. 681 (1997)

FACTS: Two days prior to the expiration of the statute of limitations, the respondent, Paula Jones, filed suit in the United States District Court for the Eastern District of Arkansas against the sitting president, William Jefferson Clinton, the petitioner in this case, and Danny Ferguson, a former Arkansas State Police officer. The complaint alleges two federal claims, and two state law claims over which the federal court has jurisdiction because of the diverse citizenship of the parties. The allegations stem from “abhorrent” sexual advances made by the petitioner against the respondent at an official conference in Little Rock, Arkansas. Respondent alleges that her superiors subsequently dealt with her in a hostile and rude manner after rejecting the petitioner’s advances. She also alleges that, after the respondent was elected President, Ferguson had defamed her with his comments to a reporter.
In response, the petitioner made a motion to dismiss on grounds of Presidential immunity. The district court denied the motion to dismiss, however the court did rule that the trial would be postponed until after the Clinton presidency. Both parties appealed this ruling. The Court of Appeals upheld the denial of the motion to dismiss, however they also ruled that the trial should not be postponed, stating “the President, like all other government officials, is subject to the same laws that apply to other members of society.”

ISSUE: Does the Constitution afford the President temporary immunity from civil damages litigation arising out of events that occurred before he took office?

REASONING: Justice Stevens: Petitioner's principal submission--that "in all but the most exceptional cases," the Constitution affords the President temporary immunity from civil damages litigation arising out of events that occurred before he took office--cannot be sustained on the basis of precedent.
Only three sitting Presidents have been defendants in civil litigation involving their actions prior to taking office. Complaints against Theodore Roosevelt and Harry Truman had been dismissed before they took office; the dismissals were affirmed after their respective inaugurations. Two companion cases arising out of an automobile accident were filed against John F. Kennedy in 1960 during the Presidential campaign. After taking office, he unsuccessfully argued that his status as Commander in Chief gave him a right to a stay under the Soldiers' and Sailors' Civil Relief Act of 1940. The motion for a stay was denied by the District Court, and the matter was settled out of court. Thus, none of those cases sheds any light on the constitutional issue before us.
The principal rationale for affording certain public servants immunity from suits for money damages arising out of their official acts is inapplicable to unofficial conduct. In cases involving prosecutors, legislators, and judges we have repeatedly explained that the immunity serves the public interest in enabling such officials to perform their designated functions effectively without fear that a particular decision may give rise to personal liability....
That rationale provided the principal basis for our holding that a former President of the United States was "entitled to absolute immunity from damages liability predicated on his official acts." Our central concern was to avoid rendering the President "unduly cautious in the discharge of his official duties."
This reasoning provides no support for an immunity for unofficial conduct. As we explained in Fitzgerald, "the sphere of protected action must be related closely to the immunity's justifying purposes." Because of the President's broad responsibilities, we recognized in that case an immunity from damages claims arising out of official acts extending to the "outer perimeter of his authority." But we have never suggested that the President, or any other official, has an immunity that extends beyond the scope of any action taken in an official capacity.
Moreover, when defining the scope of an immunity for acts clearly taken within an official capacity, we have applied a functional approach. "Frequently our decisions have held that an official's absolute immunity should extend only to acts in performance of particular functions of his office." As our opinions have made clear, immunities are grounded in "the nature of the function performed, not the identity of the actor who performed it."
Petitioner's effort to construct an immunity from suit for unofficial acts grounded purely in the identity of his office is unsupported by precedent.

DECISION: Affirmed.

RULE: No, immunities are grounded in the nature of the function performed, not the identity of the actor who performed it. Immunities apply only to official acts so that officials do not fear personal liability from execution of their official duties.

CONCURRING: Justice Breyer [omitted from text]

DISSENTING: None.

NOTES AND COMMENTS: Two cases were cited in the decision, Nixon v. Fitzgerald (1982) and Marbury v. Madison (1803). Fitzgerald was referenced in the district court decision and again in the Supreme Court’s decision. The Marbury v. Madison (1803) quotation was one of the most memorable and key parts of that decision; “it is emphatically the province of the judicial department to say what the law is.”