Impeachment trial of Samuel Chase
An impeachment trial was held in the United States Senate in 1805, coming after the impeachment of Samuel Chase by the United States House of Representatives. There had been strong partisan political motivations behind the House's impeachment of Chase, with the Thomas Jefferson-led Democratic-Republican Party aiming to weaken a judiciary that had been largely shaped by the opposing Federalist Party. Chase was acquitted in the impeachment trial, with none of the eight articles of impeachment managing to receive the two-thirds majority necessary for a conviction. The outcome helped to solidify norms of an independent judiciary and impeachments requiring more than just a disagreement between an official and the Congress.
Background
The Senate was controlled by Jeffersonian Democratic-Republicans at the time of the trial. With a 25–9 majority, they had a two-thirds supermajority hypothetically capable of securing Chase's conviction in even a party-line vote.The impeachment of Samuel Chase, an associate justice of the United States Supreme Court, was politically motivated. A high-profile affair at the time, The impeachment pitted the two major United States political parties of the era against each other amid a battle between the parties over, among other things, what the role of Federal courts should look like. The era preceding the impeachment had seen heated political battle between the Federalists, led by John Adams, and the Democratic–Republicans, led by Thomas Jefferson. The Supreme Court of the United States was regarded at the time to be strongly partisan to the Federalist Party. The impeachment was in large part a reaction to this lean of the Supreme Court. Associate Justice Chase was viewed to be the most partisan justice on the Supreme Court. He was a strong Federalist and publicly made known his opposition to President Thomas Jefferson. He had campaigned for Federalist incumbent John Adams during the 1800 presidential election.
The impeachment was also, in part, a reaction to the increase in the power of the Supreme Court in the previous years under Chief Justice John Marshall, including the landmark Marbury v. Madison decision. Democratic–Republicans saw the judiciary, and especially the Supreme Court, as an obstacle to their consolidation of power in government. When Jefferson took office, all six Supreme Court justices were Federalists, and by 1804, Jefferson had only gotten the chance to make a single appointment to fill a Supreme Court vacancy. President Jefferson, alarmed at the seizure of power by the judiciary through their claim of exclusive judicial review in Marbury v. Madison, led his party's efforts to remove the Federalists from the bench. When Thomas Jefferson took office as president in 1801, after defeating Federalist incumbent president John Adams in the 1800 presidential election, he became impatient with the independence of the judiciary. He believed that Congress or the executive should have more sway over federal judges, and believed that their appointment and removal should be more routine along the lines of other appointed public officers. The 1800 United States elections had not only seen Jefferson unseat Adams, but had also seen the Democratic–Republicans capture control of both chambers of the United States Congress in what Jefferson referred to as the "Revolution of 1800". The party had won a sizable enough number of seats in the chambers of the legislature to make the party hypothetically capable of impeaching and removing a federal official with only the votes of its own members.
Impeachment vote and adoption of articles of impeachment
Chase was impeached by the House on March 12, 1804. The following day, a special committee was appointed to draw up article of impeachment against Chase. Appointed to the committee were Congressmen John Boyle, Joseph Clay, Peter Early, Joseph Hopper Nicholson, and John Randolph of Roanoke. Seven articles of impeachment were reported to the House by Randolph on March 26, 1804, but were ordered to lie on the table and no action was taken on them before the congress entered a recess. On November 6, 1804, the articles were referred to a special committee consisting of Congressmen Joseph Clay, Peter Early, and John Randolph of Roanoke, and John Rhea. On November 30, 1804, at the end of impeachment inquiry activities, Congressman Randolph reported eight articles of impeachment to the House. On December 4, 1804, the House of Representatives held votes to adopt the eight articles of impeachment. All the counts involved Chase's work as a trial judge in lower circuit courts. In that day, Supreme Court justices had the added duty of individually serving on circuit courts. The Supreme Court's justices would only spend a small fraction of their time meeting together as appellate judges in Washington, D.C. The bulk of their time was spent acting as circuit judges in separate geographic areas of the United States. In this role they would serve in tandem with a federal district judge permanently assigned to that area's court. The Supreme Court's judges were not fond of the arrangement that saw them tasked with these circuit court duties. The heart of the allegations made against Chase was that political bias had led Chase to treat defendants and their counsel in a blatantly unfair manner. Despite the Democratic–Republican theory that impeachment did not require a criminal act, many of the articles focused on acts that were dubiously alleged to be criminal. It is unclear the exact reason that these charges were included among the articles of impeachment, but one theory is that John Randolph of Roanoke was interested in proving criminality on Chase's part, regardless of his own theory of impeachment not requiring criminality.Officers and parties
Vice President Aaron Burr (presiding officer)
Vice President Aaron Burr served as the presiding officer of the trial. At the time he had outstanding murder charges against him in two states resulting from his fatal shooting of Alexander Hamilton during the Burr–Hamilton duel. Presiding over the impeachment trial was among the last official duties Burr undertook as vice president, along with presiding over the certification of the Electoral College vote for the 1804 presidential election on February 13, 1805, in the middle of the impeachment trial. He would give his vice-presidential farewell speech to the Senate the day after the trial ended.As the trial approached, perhaps to influence how Burr would conduct the trial, Jefferson began to give Burr increased attention. Burr received several invitations to dine at the President's House. Appointed to important offices in the newly-established government of the Louisiana Territory were Burr's stepson, Burr's brother-in-law, and Burr's close friend James Wilkinson. On a similar note, Senator William Branch Giles, a chief proponent of impeaching and removing Chase, distributed a petition urging Governor George Clinton of New York to see that the murder indictment against Burr be withdrawn. Many Democratic–Republican senators obliged to sign this petition. In his book Grand Inquests, William Rehnquist opined that he saw no historical evidence that Burr was persuaded by these overtures. Burr was highly praised for his performance as the presiding officer of the trial. However, some senators were discontent with how he had acted as presiding officer, with William Plumer writing in his daily diary, "Mr. Burr is remarkably testy—he acts more of the tyrant—is impatient, passionate—scolds—he is in a rage because we do not sit longer."
Impeachment managers
After the House adopted eight articles of impeachment on December 4, 1804, it considered a motion to appoint by ballot the House managers that would act as the prosecutors in the impeachment trial before the Senate. However, a vote on this motion was postponed until the following day. On December 5, the House approved the motion and voted by ballot to appoint seven house managers. On the first ballot, six individuals met the required majority of votes to be selected as managers. Thereafter, a second ballot was held to fill the final slot. Nobody received the needed majority in this round. Speaker Nathaniel Macon opined that, per a House standing rule related to such a situation on a second ballot that he believed was applicable, the individual with the greatest plurality should be considered duly elected. As George W. Campbell had the greatest plurality on the second ballot, it was Speaker Macon's opinion that Campbell was therefore duly elected the seventh impeachment manager. However, two congressmen appealed the speaker's decision, and the House voted that the Speaker Macon's decision not to be "in order". Therefore, a third ballot was held. On with ballot, Campbell received the required majority of the vote, and was therefore elected as the seventh manager. All seven members individuals were members of the Democratic–Republican party. After the election of the impeachment managers, the House approved a motion ordering for the managers to bring the articles before the Senate. After this, a motion was approved ordering for a message to be sent by the clerk of the United States House of Representatives to the Senate to notify them that the House had appointed the impeachment managers and had directed them to carry the articles to the Senate. On December 6, 1804, Roger Nelson declined his appointment to be an impeachment manager, as he would have to absent from Washington, D.C. during the trial. Nelson was replaced with Christopher H. Clark.John Randolph of Roanoke served as the chairman and main spokesman of the impeachment managers.
Defense counsel
Chase was defended by his counsel: Robert Goodloe Harper, Joseph Hopkinson, Charles Lee, Philip Barton Key, and Luther Martin. Martin ultimately took a leading role in the defense.Former congressman James A. Bayard of Delaware declined a request to act as counsel to Chase. He believed that since the impeachment itself was partisan, it could actually harm Chase's case if his defense was presented by someone who had recently lost an election. Bayard would incidentally join the senate in November 1804, and would vote as a senator against convicting Chase. Before his death at the hands of Burr, Hamilton had also declined to act as counsel to Chase.