Trump v. Mazars USA, LLP
140 S. Ct. 2019
| SCOTUS | 2020

Background

  • In April 2019 three House committees served subpoenas on Deutsche Bank, Capital One, and Mazars seeking years of President Trump’s and affiliated entities’ financial records to support proposed legislation and oversight (money‑laundering, terrorism financing, foreign election interference, disclosure and emoluments issues).
  • The President (in his personal capacity), his children, and business entities sued to block compliance, arguing the subpoenas exceeded congressional authority and violated separation of powers; the House committees intervened to defend them.
  • District and circuit courts reached different conclusions but largely allowed the subpoenas to proceed; the Supreme Court granted certiorari, stayed enforcement, and set the case for decision.
  • The Court recognized this is the first time it has adjudicated congressional subpoenas seeking a President’s personal records and emphasized two‑century historical practice of interbranch negotiation over document disputes.
  • The Court rejected applying the heightened Nixon/Senate‑Select‑Committee standards (developed for executive‑privileged Oval Office materials) to nonprivileged personal records, but held that subpoenas for a President’s information require a separation‑of‑powers sensitive, searching judicial review.
  • The Court vacated the courts of appeals’ judgments and remanded, outlining special considerations courts must apply: whether Congress really needs the President’s records (no adequate alternative sources), narrow tailoring, substantive evidence of legislative purpose, and careful assessment of burdens on the President; separate dissents would have barred legislative subpoenas for private, nonofficial documents (Justice Thomas) or required a more demanding showing from the House (Justice Alito).

Issues

Issue Plaintiff's Argument (Trump) Defendant's Argument (House) Held
1) Whether House committees may subpoena the President's personal financial records under Congress's legislative inquiry power Subpoenas lack a valid legislative purpose; are a pretext to harass, investigate wrongdoing (a law‑enforcement function) and breach separation of powers Subpoenas serve legitimate legislative/oversight aims (banking law, AML/terrorism financing, foreign influence, disclosure, emoluments) Courts must review subpoenas for President’s records with special separation‑of‑powers care; not categorically barred but subject to heightened, context‑sensitive scrutiny
2) What standard governs judicial review of such subpoenas (Nixon/special prosecutor standard vs ordinary legislative relevance test) Nixon‑level “demonstrated, specific need” should apply because of the Presidency’s unique position Ordinary legislative‑purpose/relevance standard suffices; these are routine oversight subpoenas Nixon’s exacting privilege‑context standard does not apply to nonprivileged personal records; but ordinary tests are supplemented by special considerations because of interbranch conflict
3) What special considerations should courts apply when subpoenas target the President’s information Not necessary to treat President differently when documents are personal; normal rules govern Must account for separation‑of‑powers risk and the President’s unique position; courts should require evidence and narrow tailoring Courts must assess whether: President’s records are essential (no reasonable alternative), subpoena is no broader than necessary, Congress provides detailed evidence of legislative purpose, and burdens on the President are considered
4) Proper remedy and posture Block enforcement entirely; enjoin third parties from producing documents Allow enforcement consistent with committee jurisdiction and ordinary subpoena law Vacated the courts of appeals’ judgments and remanded for proceedings applying the Court’s separation‑of‑powers sensitive framework; lower courts must reassess scope and justification

Key Cases Cited

  • United States v. Nixon, 418 U.S. 683 (1974) (executive‑privilege framework for Oval Office materials; requires exacting showing where privilege asserted)
  • McGrain v. Daugherty, 273 U.S. 135 (1927) (Congressional power to investigate as auxiliary to legislation; relevance test for subpoenas)
  • Watkins v. United States, 354 U.S. 178 (1957) (limits on congressional investigations; subpoenas must further a legitimate legislative task)
  • Quinn v. United States, 349 U.S. 155 (1955) (congressional subpoenas cannot be for law enforcement; must have valid legislative purpose)
  • Eastland v. United States Servicemen's Fund, 421 U.S. 491 (1975) (scope of congressional investigatory power tied to legislative purpose)
  • Kilbourn v. Thompson, 103 U.S. 168 (1881) (early limit on congressional power to inquire into private affairs; distinguished Parliament)
  • Clinton v. Jones, 520 U.S. 681 (1997) (President subject to civil litigation and usual discovery for private actions)
  • Youngstown Sheet & Tube Co. v. Sawyer, 343 U.S. 579 (1952) (ramifications of interbranch conflict; separation‑of‑powers context)
  • NLRB v. Noel Canning, 573 U.S. 513 (2014) (respect for historical practice and comity between political branches)
  • Cheney v. United States Dist. Court for D.C., 542 U.S. 367 (2004) (courts should avoid unnecessary constitutional confrontation with the Executive)
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