Trump v. Mazars USA, LLP

Trump v. Mazars USA, LLP
Supreme Court of the United States
Argued May 12, 2020 Decided July 9, 2020
Full case name	Donald J. Trump, et al. v. Mazars USA, LLP and Committee on Oversight and Reform of the U.S. House of Representatives
Docket no.	19-715
Citations	591 U.S. ___ (more) 140 S. Ct. 2019
Case history
Prior	Preliminary injunction denied, Trump v. Comm. on Oversight and Reform, 380 F. Supp. 3d 76 (D.D.C. 2019); affirmed, 940 F.3d 710, No. 19-5142 (D.C. Cir. 2019); rehearing en banc denied, (D.C. Cir. Nov. 13, 2019); stay granted, Application No. 19A545 (S. Ct. 2019); cert. granted, consolidated with Second Circuit's Donald J. Trump, et al. v. Deutsche Bank AG, et al., No. 19-760 (S. Ct. 2019)[1]
Holding
The courts below did not take adequate account of the significant separation of powers concerns implicated by congressional subpoenas for the President's information.
Court membership
Chief Justice John Roberts Associate Justices Clarence Thomas · Ruth Bader Ginsburg Stephen Breyer · Samuel Alito Sonia Sotomayor · Elena Kagan Neil Gorsuch · Brett Kavanaugh
Case opinions
Majority	Roberts, joined by Ginsburg, Breyer, Sotomayor, Kagan, Gorsuch, Kavanaugh
Dissent	Thomas
Dissent	Alito

Trump v. Mazars USA, LLP, 591 U.S. ___ (2020) was a landmark US Supreme Court case involving subpoenas issued by committees of the US House of Representatives to obtain the tax returns of President Donald Trump, who had litigated against his personal accounting firm to prevent this disclosure, although the committees had been cleared by the United States Court of Appeals for the District of Columbia Circuit.^[1] Mazars was consolidated with Trump v. Deutsche Bank AG (591 U.S. ___, docket 19-760).

In a 7–2 decision issued on July 9, 2020, the Supreme Court held that courts must take into account separation of powers in resolving disputes over congressional subpoenas seeking the personal information of the president, and set out a number of factors to consider in evaluating the worthiness of such subpoena requests. The Supreme Court ruled that the lower court had not properly considered the separation of powers concerns; it vacated the lower court's decision and remanded the case back to the Circuit Court for review. The Supreme Court decided that the case raised questions of separation of powers, rather than executive privilege. It also noted that to request presidential documents like tax returns, Congress needs a legislative reason and may not conduct a criminal investigation, which is a power of the executive branch.^[2] Before the lower court reviewed the case, the subpoenas in question expired with the end of the 116th Congress on January 3, 2021,^[3] and on February 23, 2021, the House Committee in the 117th Congress reissued the subpoena to Mazars for the same documents it had previously sought.^[4]

Legal scholar Marty Lederman described Mazars as more important than Trump v. Vance, which was decided the same day. Lederman described Trump's argument that Congress entirely lacks "constitutional authority to investigate a sitting President's possible conflicts of interest and violations of law" as an "alarming" assertion that "would, if credited, be a radical departure from our constitutional history and tradition."^[5]