Is a President’s Defiance of a Court Order an ‘Official Act’?

Today’s wonderfully named decision “Trump v. United States” on Presidential immunity for political acts is a little more complicated than the reporting I’ve seen would indicate. It is true that the President has no immunity for “non-official acts” — at least as determined by this Supreme Court, which is both inconsistent and partisan to the point where conceivably Trump and Biden could do the same exact thing and the former would be judged to have been acting “officially” and Biden “non-officially,” thus representing a final victory against accountability for Republicans but not Democrats. But then it gets a bit more complicated. Here’s the money quote from the Court’s own summary:

Under our constitutional structure of separated powers, the nature of Presidential power entitles a former President to absolute immunity from criminal prosecution for actions within his conclusive and preclusive constitutional authority. And he is entitled to at least presumptive immunity from prosecution for all his official acts.

https://www.supremecourt.gov/opinions/23pdf/23-939_e2pg.pdf

My first reaction to this paragraph was that couching this result in the separation of government powers seemed like a twisted joke, as it arguably does no such thing. President Biden has been hemmed down time and again by court orders that he not act in various areas, notably environmental protections, or risk violating the law. Well, deciding whether to respect a court order or declare an emergency that might (or might not) supersede it surely seems like an official act! So this opinion might be read to confer the ability to ignore judicial orders — as rejected 221 years ago in the germinal case of Marbury vs. Madison — to the judicial draft (at least for Presidents with whom the court did not personally agree. That show no respect for the doctrine of separation of powers between co-equal branches of the federal government.

Fortunately — at least I think so — the court’s analysis doesn’t stop there. It divides immunity for official acts into two distinct (ok, perhaps distinct) categories: (1) those within his conclusive and preclusive constitutional authority and (2) all other official acts. For the latter, the President has only “presumptive” immunity — and the nature of presumptions in law is that they can be rebutted. The question becomes “when and how.” And that, of course becomes an issue to do the one argument that can’t really be argued to the court — that they themselves have become illegitimate due to their partisanship and inconsistency. Thus, they may always judge Trump as generally within bounds and Biden as only presumptively so — such that the final execution of a Presidential order or action might well be stayed for as long as it takes to wind through the political system. As we’ve seen, that that can take years and years!

OJB cannot be held responsible for your children’s nightmares if you let them see this. (And no, the figure on the right is not supposed to be Melania. She’s the bird at the left. Yes, that’s Steve Bannon above her.)

As the two Democratic authors of written dissents — a superlative one for the ages by Justice Sotomayor and a trenchant but shorter one by Justice Jackson — conclude, the majority is disingenuous in how far it is opening the door to Presidential immunity from critical conduct. They claim to have left room for prosecution in the area I identify above where they say that the immunity is rebuttably presumptive. Two problems with that:

  • (1) as Justice Barrett. who concurred partially with a dissent from the part of the Chief Justice’s ruling opinion that states that actual evidence of the underlying crime cannot be submitted to the jury (!), notes that if a President wants evidence to be excluded, they can seek a protective order under existing process. This common sense notion is as of today not part of the law of presidential immunity.
  • (2) One of the two Democratic dissenters notes that as soon as the majority opens the door for the presumption for immunity to be limited by rebuttal evidence, it closes the door on the possibility with additional parts of the motion.

So as of this point, my tentative conclusion is that yes, the President can ignore a court order and get away with it — but only if the majority of the Justices agree with the result. That’s what we end up with when our Supreme Court becomes our Supremely Political Court.

I’m going to add more and more to this piece as time permits this week for deeper reading of the various decisions, but I want to open it up to commentary now. This is NOT an Open Thread. (Presumptively.)

About Greg Diamond

Somewhat verbose attorney, semi-disabled and semi-retired, residing in northwest Brea. Occasionally ran for office against jerks who otherwise would have gonr unopposed. Got 45% of the vote against Bob Huff for State Senate in 2012; Josh Newman then won the seat in 2016. In 2014 became the first attorney to challenge OCDA Tony Rackauckas since 2002; Todd Spitzer then won that seat in 2018. Every time he's run against some rotten incumbent, the *next* person to challenge them wins! He's OK with that. Corrupt party hacks hate him. He's OK with that too. He does advise some local campaigns informally and (so far) without compensation. (If that last bit changes, he will declare the interest.) His daughter is a professional campaign treasurer. He doesn't usually know whom she and her firm represent. Whether they do so never influences his endorsements or coverage. (He does have his own strong opinions.) But when he does check campaign finance forms, he is often happily surprised to learn that good candidates he respects often DO hire her firm. (Maybe bad ones are scared off by his relationship with her, but they needn't be.)