Us Congress 2025-2026 Regular Session

Us Congress House Bill HR353 Compare Versions

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11 IV
22 119THCONGRESS
33 1
44 STSESSION H. RES. 353
55 Impeaching Donald John Trump, President of the United States, for high
66 crimes and misdemeanors.
77 IN THE HOUSE OF REPRESENTATIVES
88 APRIL28, 2025
99 Mr. T
1010 HANEDAR(for himself, Mr. MFUME, Mr. NADLER, and Ms. KELLYof
1111 Illinois) submitted the following resolution; which was referred to the
1212 Committee on the Judiciary
1313 RESOLUTION
1414 Impeaching Donald John Trump, President of the United
1515 States, for high crimes and misdemeanors.
1616 Resolved, That Donald John Trump, President of the 1
1717 United States, is impeached for high crimes and mis-2
1818 demeanors, and that the following articles of impeachment 3
1919 be exhibited to the Senate: 4
2020 Article of impeachment exhibited by the House of 5
2121 Representatives of the United States of America in the 6
2222 name of itself and of the people of the United States of 7
2323 America, against Donald John Trump, President of the 8
2424 United States of America, in maintenance and support of 9
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2828 its impeachment against him for high crimes and mis-1
2929 demeanors. 2
3030 ARTICLE I: OBSTRUCTION OF JUSTICE , VIOLATION OF 3
3131 DUE PROCESS, AND A BREACH OF THE DUTY TO 4
3232 FAITHFULLY EXECUTE LAWS 5
3333 6
3434 The Constitution provides that the House of Rep-7
3535 resentatives ‘‘shall have the sole Power of Impeachment’’ 8
3636 and that the President ‘‘shall be removed from Office on 9
3737 Impeachment for, and Conviction of, Treason, Bribery, or 10
3838 other high Crimes and Misdemeanors’’. Further, Article 11
3939 II of the Constitution states that the President ‘‘shall take 12
4040 Care that the Laws be faithfully executed’’, the Fourth 13
4141 Amendment of the Constitution states that ‘‘The right of 14
4242 the people . . . against unreasonable searches and sei-15
4343 zures, shall not be violated’’, and the Fifth Amendment 16
4444 of the Constitution states ‘‘No person shall be . . . de-17
4545 prived of life, liberty, or property, without due process of 18
4646 law’’. In his conduct of the office of President of the 19
4747 United States—and in violation of his constitutional oath 20
4848 to faithfully to execute the office of President of the 21
4949 United States and, to the best of his ability, preserve, pro-22
5050 tect, and defend the Constitution of the United States, 23
5151 and in violation of his constitutional duty to take care that 24
5252 the laws be faithfully executed—Donald John Trump has 25
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5656 abused the powers of the Presidency in a manner offensive 1
5757 to, and subversive of, the Constitution, in that: 2
5858 Using the power of his high office, Donald John 3
5959 Trump has engaged in this scheme or course of conduct 4
6060 through the following means: 5
6161 (1) By his orders and directions to subordi-6
6262 nates, obstructed the administration of justice and 7
6363 embarked on a scheme to destroy and corrupt the 8
6464 legal system and the powers of the courts under Ar-9
6565 ticle III of the Constitution. Specifically, he has done 10
6666 the following: 11
6767 (A) Directed and permitted his subordi-12
6868 nates and attorneys at the Department of Jus-13
6969 tice to violate their oaths to uphold the Con-14
7070 stitution, laws of the United States, and the 15
7171 rules of professional ethics by adducing mis-16
7272 leading and willfully false representations to the 17
7373 courts of the United States, and to otherwise 18
7474 abuse their official powers. Specifically, he 19
7575 has— 20
7676 (i) sought to dismiss, without preju-21
7777 dice and under false pretenses, the bribery 22
7878 and fraud charges against New York City 23
7979 Mayor Eric Adams, in an unethical quid 24
8080 pro quo exchange for the Defendant’s co-25
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8484 operation with the Administration’s polit-1
8585 ical priorities, thus abusing the criminal 2
8686 laws to unconstitutionally commandeer a 3
8787 State officer and unit of government in 4
8888 violation of the sovereignty thereof; and 5
8989 (ii) terminated and purged career De-6
9090 partment of Justice attorneys without rea-7
9191 sonable cause and in violation of the law in 8
9292 retaliation for their legitimate investigatory 9
9393 and prosecutorial work under prior admin-10
9494 istrations, including in relation to the Jan-11
9595 uary 6, 2021, attack on the United States 12
9696 Capitol, and in retaliation for attorneys 13
9797 upholding their ethical and legal obliga-14
9898 tions including candor and honesty to the 15
9999 courts. 16
100100 (B) Directed and permitted the evasion 17
101101 and defiance of binding court orders. Specifi-18
102102 cally, he has— 19
103103 (i) removed persons from the United 20
104104 States to El Salvador despite an order 21
105105 from the United States District Court for 22
106106 the District of Columbia, for which said 23
107107 Court has found probable cause that the 24
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111111 Government committed acts of criminal 1
112112 contempt; 2
113113 (ii) removed Kilmar Armando Abrego 3
114114 Garcia from the United States to El Sal-4
115115 vador despite a binding Withholding of Re-5
116116 moval order prohibiting the government 6
117117 from removing him to El Salvador; 7
118118 (iii) defied court orders, upheld by a 8
119119 unanimous ruling of the Supreme Court, to 9
120120 facilitate the release of Mr. Abrego Garcia, 10
121121 and related orders to provide information 11
122122 to the court and opposing counsel, while 12
123123 publicly flaunting their refusal; 13
124124 (iv) acted in contempt of court for vio-14
125125 lating a court-sanctioned settlement agree-15
126126 ment; and 16
127127 (v) conducted enforced disappearances 17
128128 of persons without due process and without 18
129129 disclosing their fate and location to their 19
130130 families and legal counsel, in violation of 20
131131 the Constitution and the rulings of the Su-21
132132 preme Court, as well as the foundational 22
133133 principles of due process and the rule of 23
134134 law. 24
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138138 (C) Directed and permitted the deliberate 1
139139 and systematic violation of laws duly enacted by 2
140140 Congress. Specifically, he has— 3
141141 (i) terminated Inspector Generals, the 4
142142 officers responsible for detecting and pre-5
143143 venting waste by auditing and inves-6
144144 tigating their respective agencies’ oper-7
145145 ations and personnel, in violation of the 8
146146 process stipulated by the Inspector Gen-9
147147 erals Act of 1974, as subsequently amend-10
148148 ed; 11
149149 (ii) terminated a member of the Merit 12
150150 Systems Protection Board, a tribunal cre-13
151151 ated to address widespread public concerns 14
152152 about the Federal civil service; and 15
153153 (iii) unlawfully transmitted sensitive 16
154154 personal information of private citizens 17
155155 and government employees in violation of, 18
156156 among other Federal laws, the Privacy Act 19
157157 and the Administrative Procedure Act. 20
158158 In all of this, Donald John Trump has willfully dis-21
159159 regarded Federal laws and the Constitution, imperiled a 22
160160 coequal branch of Government, and threatened the integ-23
161161 rity of the democratic system. He thereby betrayed his 24
162162 trust as President, abused the powers of the Presidency, 25
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166166 acted in a manner grossly incompatible with self-govern-1
167167 ance and the rule of law, and has committed the High 2
168168 Crimes and Misdemeanors of obstruction of justice and 3
169169 effecting a wide-ranging scheme to destroy and corrupt 4
170170 the legal system and the powers of the courts under Article 5
171171 III of the Constitution. 6
172172 Wherefore, Donald John Trump, by such conduct, 7
173173 has demonstrated that he is unfit to govern a Nation by 8
174174 and for the people, has acted in a manner grossly incom-9
175175 patible with self-governance and the rule of law, and will 10
176176 remain a threat to the Constitution if allowed to remain 11
177177 in office. 12
178178 ARTICLE II: USURPATION OF THE APPROPRIATIONS 13
179179 POWER 14
180180 15
181181 The Constitution provides that the House of Rep-16
182182 resentatives ‘‘shall have the sole Power of Impeachment’’ 17
183183 and that the President ‘‘shall be removed from Office on 18
184184 Impeachment for, and Conviction of, Treason, Bribery, or 19
185185 other high Crimes and Misdemeanors’’. Further, Section 20
186186 9 of Article I of the Constitution states that ‘‘No money 21
187187 shall be drawn from the Treasury, but in Consequence of 22
188188 Appropriations made by Law’’. In his conduct of the office 23
189189 of President of the United States—and in violation of his 24
190190 constitutional oath to faithfully to execute the office of 25
191191 President of the United States and, to the best of his abil-26
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195195 ity, preserve, protect, and defend the Constitution of the 1
196196 United States, and in violation of his constitutional duty 2
197197 to take care that the laws be faithfully executed—Donald 3
198198 John Trump has abused the powers of the Presidency in 4
199199 a manner offensive to, and subversive of, the Constitution, 5
200200 in that: 6
201201 Using the powers of his high office, Donald John 7
202202 Trump unlawfully usurped Congress and its power to ap-8
203203 propriate funds, thereby nullifying the Appropriations 9
204204 Clause in the Constitution and violating the Impoundment 10
205205 Control Act of 1974. Since taking office, he has signed 11
206206 numerous Executive Orders directing agencies to withhold 12
207207 funds appropriated by Congress. The President does not 13
208208 have the power to override spending laws or impound ap-14
209209 propriated funds, a principle affirmed by numerous Su-15
210210 preme Court rulings. 16
211211 Donald John Trump has withheld funds and termi-17
212212 nated en masse Federal employees and numerous Federal 18
213213 agencies and departments, including the following: 19
214214 (1) Directed the dismantling of the Department 20
215215 of Education. As enacted in the Department of Edu-21
216216 cation Organization Act, signed into law by Presi-22
217217 dent Jimmy Carter, the Department of Education 23
218218 was established by Congress to create reform in the 24
219219 education system throughout the country, distribute 25
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223223 Federal aid to students and places of learning, and 1
224224 prohibit discriminatory practices. The President does 2
225225 not have the authority to dismantle the Department 3
226226 of Education, and his signing of Executive Order 4
227227 14242, which aims to ‘‘Improving Education Out-5
228228 comes by Empowering Parents, States, and Commu-6
229229 nities’’, violates the law and the Constitution. 7
230230 (2) Unlawfully directed the elimination of the 8
231231 United States Agency for International Development 9
232232 (USAID). As enacted in the Foreign Assistance Act 10
233233 of 1961, signed into law by President John F. Ken-11
234234 nedy, USAID plays a crucial role in delivering for-12
235235 eign assistance worldwide, including disaster relief, 13
236236 conflict relief, combating global diseases, promoting 14
237237 educational programs, and enhancing food security 15
238238 in developing countries. By dismantling USAID and 16
239239 freezing foreign assistance, he has severed the 17
240240 United States from its humanitarian role as directed 18
241241 by Congress, leaving other countries and potentially 19
242242 our adversaries to fill in the role the United States 20
243243 has abandoned. 21
244244 (3) Created the so-called ‘‘Department of Gov-22
245245 ernment Efficiency (DOGE)’’, which has imposed 23
246246 payment holds and rescinded funds after disburse-24
247247 ment. Donald John Trump has utilized DOGE to 25
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251251 unlawfully block or impound appropriated funds to 1
252252 dozens of Federal agencies, including the National 2
253253 Institutes of Health, the Federal Aviation Adminis-3
254254 tration, and the Department of Veterans Affairs. By 4
255255 impounding congressionally appropriated funds, 5
256256 Donald John Trump and DOGE have not only vio-6
257257 lated the law, but have negatively impacted the 7
258258 American people by cutting jobs, halting critical 8
259259 services, and rescinding grants for programs, in defi-9
260260 ance of the express, constitutionally binding will of 10
261261 Congress. 11
262262 Using the powers of his high office, Donald John 12
263263 Trump has unlawfully withheld congressionally appro-13
264264 priated funds and attempted to dismantle congressionally 14
265265 mandated agencies. By withholding funds and crippling 15
266266 agencies, he has prevented the Federal Government from 16
267267 performing critical duties here and abroad. He has threat-17
268268 ened the well-being of United States citizens through the 18
269269 gross misconduct of his office, resulting in dire and life- 19
270270 threatening consequences on the world’s most vulnerable 20
271271 populations. 21
272272 Wherefore, Donald John Trump, by such conduct, 22
273273 has demonstrated that he is unfit to govern a Nation by 23
274274 and for the people, has acted in a manner grossly incom-24
275275 patible with self-governance and the rule of law, and will 25
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279279 remain a threat to the Constitution if allowed to remain 1
280280 in office. 2
281281 ARTICLE III: ABUSE OF TRADE POWERS AND 3
282282 INTERNATIONAL AGGRESSION 4
283283 5
284284 The Constitution provides that the House of Rep-6
285285 resentatives ‘‘shall have the sole Power of Impeachment’’ 7
286286 and that the President ‘‘shall be removed from Office on 8
287287 Impeachment for, and Conviction of, Treason, Bribery, or 9
288288 other high Crimes and Misdemeanors’’. Further, Section 10
289289 8 of Article I of the Constitution states, ‘‘Congress shall 11
290290 have Power To lay and collect Taxes, Duties, Imposts and 12
291291 Excises, . . . but all Duties, Imposts and Excises shall 13
292292 be uniform throughout the United States’’. In his conduct 14
293293 of the office of President of the United States—and in 15
294294 violation of his constitutional oath to faithfully to execute 16
295295 the office of President of the United States and, to the 17
296296 best of his ability, preserve, protect, and defend the Con-18
297297 stitution of the United States, and in violation of his con-19
298298 stitutional duty to take care that the laws be faithfully 20
299299 executed—Donald John Trump has abused the powers of 21
300300 the Presidency in a manner offensive to, and subversive 22
301301 of, the Constitution, in that: 23
302302 Using the powers of his high office, Donald John 24
303303 Trump abused trade powers by imposing unjustifiable and 25
304304 unreasonable tariffs on foreign nations, causing a sharp 26
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308308 decline in the United States economy and the economies 1
309309 of countries around the world, and declaring the false ex-2
310310 istence of a national security emergency to justify his ac-3
311311 tions. Donald John Trump’s tariffs contradicted trade 4
312312 agreements established by his Administration and other 5
313313 administrations, including the duly ratified and binding 6
314314 treaty obligations of the United States, thereby breaking 7
315315 international laws and norms, leading to countries around 8
316316 the world to enact damaging tariffs on goods and services 9
317317 originating from the United States. His ‘‘Liberation Day’’ 10
318318 scheme, which imposed 10 percent tariffs on all countries, 11
319319 as well as additional tariffs based on a formula for ‘‘reci-12
320320 procity’’ widely mocked as nonsensical, led to the most sig-13
321321 nificant drop in the financial markets since the 2020 crash 14
322322 triggered by the COVID–19 pandemic. 15
323323 Additionally, Donald John Trump has threatened for-16
324324 eign nations with invasion, the annexation of territory, 17
325325 and the occupation of sovereign territory through the use 18
326326 of military action. By doing this, he has implicated the 19
327327 United States and himself in violation of constitutionally 20
328328 binding treaty obligations, to include the North Atlantic 21
329329 Treaty of 1949, the General Treaty for Renunciation of 22
330330 War as an Instrument of National Policy of 1928, the 23
331331 Charter of the United Nations of 1945, and the Inter- 24
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335335 American Treaty of Reciprocal Assistance of 1947. Don-1
336336 ald John Trump threatened the following: 2
337337 (1) Annexation of the sovereign country of Can-3
338338 ada. Donald John Trump has negatively impacted 4
339339 the deep and historic relationship between the 5
340340 United States and Canada by stating numerous 6
341341 times that Canada should become the 51st State, 7
342342 under the threat of both economic coercion and mili-8
343343 tary force. 9
344344 (2) Unlawful and aggressive military action 10
345345 within Mexico, to include drone strikes and the use 11
346346 of special operations military personnel, ostensibly 12
347347 against drug cartels, in violation of the sovereignty 13
348348 and territorial integrity of that country and without 14
349349 any congressional authorization to use military force. 15
350350 (3) Annexation of Greenland, an autonomous 16
351351 territory in the Kingdom of Denmark. Donald John 17
352352 Trump has continued to use hostile language aimed 18
353353 at taking control of Greenland, stating that the 19
354354 United States will ‘‘go as far as we have to go’’ to 20
355355 obtain control of Greenland. He has refused to rule 21
356356 out military action to gain control of the territory, 22
357357 in violation of international law and despite Den-23
358358 mark’s longstanding alliance and friendly relations 24
359359 with the United States. 25
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363363 (4) Annexation of the Panama Canal, owned 1
364364 and controlled by Panama. During a joint session 2
365365 speech to Congress, Donald John Trump stated that 3
366366 his Administration ‘‘will be reclaiming the Panama 4
367367 Canal’’. He has refused to rule out military or eco-5
368368 nomic action against the sovereign country. 6
369369 (5) Annexation of the Gaza Strip, involving the 7
370370 forced resettlement of the Palestinian population to 8
371371 the surrounding countries. Donald John Trump has 9
372372 stated that the United States ‘‘will take over the 10
373373 Gaza Strip’’ and ‘‘own it’’. His proposal of taking 11
374374 over the Gaza Strip and the expulsion of its popu-12
375375 lation violates international law, including the Con-13
376376 vention on the Prevention and Punishment of the 14
377377 Crime of Genocide, would be unconstitutional absent 15
378378 the approval of the United States Congress, and is 16
379379 profoundly unserious in light of the grave humani-17
380380 tarian situation and ongoing armed conflict in Gaza. 18
381381 Using the powers of his high office, Donald John 19
382382 Trump has unlawfully conducted himself, bringing shame 20
383383 and embarrassment to the office of the Presidency and 21
384384 the people of the United States. He has betrayed the trust 22
385385 of the Nation to conduct meaningful diplomatic negotia-23
386386 tions as its chief diplomat and failed to maintain peaceful 24
387387 economic and defense relations with foreign countries. He 25
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391391 has threatened the security of the United States through 1
392392 gross misconduct of his office, prompting hostilities to-2
393393 wards Americans here and abroad, as well as foreign na-3
394394 tions warning their citizens against visiting the United 4
395395 States, further harming the Nation’s economy. 5
396396 Wherefore, Donald John Trump, by such conduct, 6
397397 has demonstrated that he is unfit to govern a Nation by 7
398398 and for the people, has acted in a manner grossly incom-8
399399 patible with self-governance and the rule of law, and will 9
400400 remain a threat to the Constitution if allowed to remain 10
401401 in office. 11
402402 ARTICLE IV: VIOLATION OF FIRST AMENDMENT RIGHTS 12
403403 13
404404 The Constitution provides that the House of Rep-14
405405 resentatives ‘‘shall have the sole Power of Impeachment’’ 15
406406 and that the President ‘‘shall be removed from Office on 16
407407 Impeachment for, and Conviction of, Treason, Bribery, or 17
408408 other high Crimes and Misdemeanors’’. Further, the First 18
409409 Amendment of the Constitution states ‘‘Congress shall 19
410410 make no law respecting an establishment of religion, or 20
411411 prohibiting the free exercise thereof; or abridging the free-21
412412 dom of speech, or of the press; or the right of the people 22
413413 peaceably to assemble, and to petition the Government for 23
414414 a redress of grievances’’. In his conduct of the office of 24
415415 President of the United States—and in violation of his 25
416416 constitutional oath to faithfully to execute the office of 26
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420420 President of the United States and, to the best of his abil-1
421421 ity, preserve, protect, and defend the Constitution of the 2
422422 United States, and in violation of his constitutional duty 3
423423 to take care that the laws be faithfully executed—Donald 4
424424 John Trump has abused the powers of the Presidency in 5
425425 a manner offensive to, and subversive of, the Constitution, 6
426426 in that: 7
427427 By his orders and directions to subordinates, retali-8
428428 ated against law firms and attorneys who have advised or 9
429429 represented, or been associated with those who advise or 10
430430 represent, litigants who displease him, in violation of the 11
431431 Constitution’s prohibition on retaliation against individ-12
432432 uals for engaging in First Amendment-protected conduct, 13
433433 including the right to petition the government for redress 14
434434 of grievances. Specifically, he has, barred attorneys at cer-15
435435 tain law firms from access to Federal buildings, arbitrarily 16
436436 revoked security clearances without a reasonable basis, 17
437437 threatened to cancel Federal contracts with any entity en-18
438438 gaging the targeted attorneys and firms, and demanded 19
439439 pro bono services from law firms in exchange for the dis-20
440440 continuation of the punitive Executive orders. 21
441441 Additionally, Donald John Trump has engaged in a 22
442442 pattern of unconstitutional, unlawful, and corrupt retalia-23
443443 tion against critics and political opponents, a flagrant vio-24
444444 lation of constitutional rights protected by the First 25
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448448 Amendment. He has weaponized the Department of Jus-1
449449 tice and other agencies to engage in spurious investiga-2
450450 tions and harassment, with no basis in law, of public fig-3
451451 ures and his perceived political enemies. 4
452452 Since taking office, Donald John Trump has directed 5
453453 the Department of Justice to dismiss more than a dozen 6
454454 prosecutors who were involved in investigations against 7
455455 him after he left office in 2021. The Department of Jus-8
456456 tice has subsequently launched investigations into officials 9
457457 involved in prior probes against Donald John Trump, in 10
458458 some cases against individuals specifically named and ac-11
459459 cused in flagrantly improper Executive orders. 12
460460 Furthermore, he has made direct and unambiguous 13
461461 public statements threatening media outlets, current and 14
462462 former officeholders, and advocacy organizations. He has 15
463463 pursued meritless litigation, leveraged his public office for 16
464464 private gain, and perverted the course of justice and the 17
465465 integrity of the judicial system to extract tens of millions 18
466466 of dollars in putative settlements, effectively acting as a 19
467467 conduit for flagrant bribery and extortion. He has re-20
468468 stricted the access of the Associated Press after they re-21
469469 fused to use the name ‘‘Gulf of America’’ in their report-22
470470 ing and has defied court orders to cease this unconstitu-23
471471 tional action. He has also threatened current and former 24
472472 members of Congress for the exercise of their legislative 25
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476476 and oversight functions, an attack on the independence of 1
477477 Congress as a coequal branch of government as estab-2
478478 lished by the Constitution’s Article I Vesting Clause, and 3
479479 by the Constitution’s Speech or Debate Clause, in addition 4
480480 to the First Amendment. 5
481481 For example, Donald John Trump has repeatedly 6
482482 threatened members of the House Select Committee on 7
483483 the January 6th Attack on the United States Capitol, 8
484484 which investigated the attack on the Capitol that Donald 9
485485 John Trump instigated. Donald John Trump has sought 10
486486 to intimidate the members and staff of the United States 11
487487 House Select Committee on the January 6th Attack, stat-12
488488 ing that they ‘‘should fully understand that they are sub-13
489489 ject to investigation at the highest level’’ and expressing 14
490490 a desire to remove the pardons they received, stating ‘‘The 15
491491 ‘Pardons’ that Sleepy Joe Biden gave to the Unselect 16
492492 Committee of Political Thugs, and many others, are here-17
493493 by declared [void, vacant, and of no further force or ef-18
494494 fect]’’. 19
495495 Donald John Trump has made it clear that he will 20
496496 not rest until all of his perceived political enemies are 21
497497 eliminated. In a speech addressing his Department of Jus-22
498498 tice subordinates, Donald John Trump further laid out his 23
499499 fascist vision for the Department of Justice. He has tar-24
500500 geted watchdog organizations like the Citizens for Respon-25
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504504 sibility and Ethics in Washington, calling them ‘‘scum’’ 1
505505 and independent media outlets like CNN and MSNBC, la-2
506506 belling them as organizations that ‘‘literally write 97.6 3
507507 percent bad about me, are political arms of the Democrat 4
508508 Party. And in my opinion, they are really corrupt and they 5
509509 are illegal. What they do is illegal.’’. He has stated that 6
510510 newspapers critical of him are ‘‘really no different than 7
511511 a highly paid political operative. And it has to stop. It 8
512512 has to be illegal. It’s influencing judges . . . it just cannot 9
513513 be legal.’’. 10
514514 By these and many other actions, he has sought to 11
515515 outlaw dissent, opposition, and criticism of himself and his 12
516516 Administration. This attack on the constitutional rights 13
517517 to freedom of speech, and of association, and of the right 14
518518 to petition the government for redress of grievances, is 15
519519 wholly incompatible with the rights and liberties of the 16
520520 People of the United States as a self-governing people 17
521521 under the rule of law. 18
522522 In purpose and effect, he has attempted to suppress 19
523523 dissent and opposition, casting a chilling effect over the 20
524524 public discourse, and striking at the core freedoms essen-21
525525 tial to a free society and democratic elections under the 22
526526 Constitution. 23
527527 Wherefore, Donald John Trump, by such conduct, 24
528528 has demonstrated that he is unfit to govern a Nation by 25
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532532 and for the people, has acted in a manner grossly incom-1
533533 patible with self-governance and the rule of law, and will 2
534534 remain a threat to the Constitution if allowed to remain 3
535535 in office. 4
536536 ARTICLE V: CREATION OF UNLAWFUL OFFICE 5
537537 6
538538 The Constitution provides that the House of Rep-7
539539 resentatives ‘‘shall have the sole Power of Impeachment’’ 8
540540 and that the President ‘‘shall be removed from Office on 9
541541 Impeachment for, and Conviction of, Treason, Bribery, or 10
542542 other high Crimes and Misdemeanors’’. Further, Section 11
543543 2 of Article II of the Constitution states that the President 12
544544 ‘‘shall appoint Ambassadors, other public Ministers and 13
545545 Consuls, Judges of the supreme Court, and all other Offi-14
546546 cers of the United States . . . but the Congress may by 15
547547 Law vest the Appointment of such inferior Officers, as 16
548548 they think proper, in the President alone, in the Courts 17
549549 of Law, or in the Heads of Departments’’. In his conduct 18
550550 of the office of President of the United States—and in 19
551551 violation of his constitutional oath to faithfully to execute 20
552552 the office of President of the United States and, to the 21
553553 best of his ability, preserve, protect, and defend the Con-22
554554 stitution of the United States, and in violation of his con-23
555555 stitutional duty to take care that the laws be faithfully 24
556556 executed—Donald John Trump has abused the powers of 25
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560560 the Presidency in a manner offensive to, and subversive 1
561561 of, the Constitution, in that: 2
562562 Using the powers of his high office, Donald John 3
563563 Trump has, through unlawful orders and directives, cre-4
564564 ated an unlawful office, the so-called Department of Gov-5
565565 ernment Efficiency (‘‘DOGE’’), and assigned an extensive 6
566566 range of unlawful powers, effectively granting this fla-7
567567 grantly unconstitutional creation significant control over 8
568568 the executive branch. Donald John Trump has appointed 9
569569 Mr. Elon Musk as the de facto head of this contrived enti-10
570570 ty, which was not created or funded by any law, without 11
571571 a formal title or office. These actions have been in direct 12
572572 violation of the Constitution’s requirement that principal 13
573573 officers of the United States must be created by law and 14
574574 their appointees confirmed by the Senate, and that inferior 15
575575 offices must be created by law with their appointment 16
576576 vested as Congress may determine. 17
577577 Additionally, he has vested these powers in Mr. Musk 18
578578 without complying with the constitutional requirement 19
579579 that all officers of the United States be commissioned by 20
580580 the President and swear an oath of office to support the 21
581581 Constitution. Mr. Musk has been designated as a special 22
582582 government employee of the White House Office, in viola-23
583583 tion of statutory authorization and restrictions on such 24
584584 designations. This false claim has also been used to com-25
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588588 mit violations of the ethics, disclosure, and conflict-of-in-1
589589 terest laws applicable to government officers and regular 2
590590 employees. 3
591591 Contrary to the Government’s claims in court, Mr. 4
592592 Musk has exercised de facto control over DOGE and, 5
593593 through it, control over a wide range of Government de-6
594594 partments and agencies. This unmistakable reality has 7
595595 been repeatedly and openly stated by the Trump Adminis-8
596596 tration, including by Donald John Trump’s own address 9
597597 to Congress on March 4, 2025. In this capacity, Mr. Musk 10
598598 and his subordinates have undertaken numerous violations 11
599599 of the Constitution and laws, including by— 12
600600 (1) impoundment of funds appropriated by 13
601601 Congress; 14
602602 (2) violations of privacy and security laws with 15
603603 respect to sensitive information systems, personally 16
604604 identifiable information, and classified material; and 17
605605 (3) termination of government employees under 18
606606 false pretenses and in violation of civil service laws. 19
607607 These actions have vastly exceeded the terms of the 20
608608 formal executive orders purporting to create DOGE under 21
609609 the direction of a ‘‘U.S. DOGE Service Administrator’’, 22
610610 an office which remained vacant for several weeks, with 23
611611 the Government’s own attorneys claiming in court that the 24
612612 official head of DOGE was unknown to them. Since that 25
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616616 time, a nominal Administrator has been named, despite 1
617617 the repeated avowals from the President and his Adminis-2
618618 tration that Mr. Musk controls and directs DOGE, as con-3
619619 firmed by ample public reporting and Mr. Musk’s own 4
620620 statements. 5
621621 Donald John Trump has abused the powers of his 6
622622 high office and breached the public trust by establishing 7
623623 the so-called Department of Government Efficiency and 8
624624 unconstitutionally placing Mr. Musk in control of this enti-9
625625 ty, knowingly provided false testimony to the court regard-10
626626 ing the leadership of the said entity, and directing the un-11
627627 lawful entity to implement his agenda, in violation of the 12
628628 Constitution’s objective of establishing Justice and funda-13
629629 mental rules for how the executive branch of the United 14
630630 States is to be structured and how persons may be ap-15
631631 pointed to public office. 16
632632 Wherefore, Donald John Trump, by such conduct, 17
633633 has demonstrated that he is unfit to govern a Nation by 18
634634 and for the people, has acted in a manner grossly incom-19
635635 patible with self-governance and the rule of law, and will 20
636636 remain a threat to the Constitution if allowed to remain 21
637637 in office. 22
638638 ARTICLE VI: BRIBERY AND CORRUPTION 23
639639 24
640640 The Constitution provides that the House of Rep-25
641641 resentatives ‘‘shall have the sole Power of Impeachment’’ 26
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645645 and that the President ‘‘shall be removed from Office on 1
646646 Impeachment for, and Conviction of, Treason, Bribery, or 2
647647 other high Crimes and Misdemeanors’’. Further, Section 3
648648 9 of Article I of the Constitution states that ‘‘no Person 4
649649 holding any Office of Profit or Trust under them, shall, 5
650650 without the Consent of the Congress, accept of any 6
651651 present, Emolument, Office, or Title, of any kind what-7
652652 ever, from any . . . foreign State’’. In his conduct of the 8
653653 office of President of the United States—and in violation 9
654654 of his constitutional oath to faithfully to execute the office 10
655655 of President of the United States and, to the best of his 11
656656 ability, preserve, protect, and defend the Constitution of 12
657657 the United States, and in violation of his constitutional 13
658658 duty to take care that the laws be faithfully executed— 14
659659 Donald John Trump has abused the powers of the Presi-15
660660 dency in a manner offensive to, and subversive of, the Con-16
661661 stitution, in that: 17
662662 Donald John Trump has engaged in a pattern of un-18
663663 lawful corruption for the personal profit of himself and 19
664664 his associates, soliciting and accepting bribes in exchange 20
665665 for official actions, policy influence, and favorable treat-21
666666 ment from the Administration. In so doing, he has, beyond 22
667667 a reasonable doubt, profiteered from public office on a 23
668668 scale unprecedented in American history. 24
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672672 Donald John Trump has engaged in fraudulent con 1
673673 artist schemes through ‘‘pump and dump’’ or ‘‘rug pull’’ 2
674674 tactics for cryptocurrency tokens he has created, and at 3
675675 the same time, enabled a direct conduit for bribes paid 4
676676 to him in exchange for official actions. 5
677677 Donald John Trump has also leveraged the threat of 6
678678 hostile government action and the corresponding offer of 7
679679 preferential treatment in order to extract large payments 8
680680 in the form of settlements for meritless and vexatious liti-9
681681 gation he pursues in his personal capacity, thereby cor-10
682682 rupting both the executive branch and the judiciary. To 11
683683 advance this end, Donald John Trump solicited and re-12
684684 ceived $940,000,000 in pro bono services from prominent 13
685685 law firms to help causes he personally supports. 14
686686 Donald John Trump has refused to divest himself or 15
687687 take any steps to prevent conflicts of interest in his sub-16
688688 stantial personal business ventures, creating another con-17
689689 duit for the payment of bribes. 18
690690 Donald John Trump has permitted and encouraged 19
691691 his subordinates to violate laws regarding ethics, disclo-20
692692 sures, and self-dealing, and through these actions, he has 21
693693 enabled and encouraged corruption and graft by his rel-22
694694 atives, associates, and political allies. 23
695695 Donald John Trump has, in these ways and others, 24
696696 solicited payments from foreign governments for corrupt 25
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700700 purposes and in flagrant violation of the Constitution’s 1
701701 prohibition on foreign emoluments. 2
702702 Wherefore, Donald John Trump, by such conduct, 3
703703 has demonstrated that he is unfit to govern a Nation by 4
704704 and for the people, has acted in a manner grossly incom-5
705705 patible with self-governance and the rule of law, and will 6
706706 remain a threat to the Constitution if allowed to remain 7
707707 in office. 8
708708 ARTICLE VII: TYRANNY 9
709709 10
710710 The Constitution provides that the House of Rep-11
711711 resentatives ‘‘shall have the sole Power of Impeachment’’ 12
712712 and that the President ‘‘shall be removed from Office on 13
713713 Impeachment for, and Conviction of, Treason, Bribery, or 14
714714 other high Crimes and Misdemeanors’’. Further, the sys-15
715715 tem of checks and balances, as well as the separation of 16
716716 powers, as defined in the Constitution, work to ensure that 17
717717 the Office of the President does not become tyrannical. 18
718718 In his conduct of the office of President of the United 19
719719 States—and in violation of his constitutional oath to faith-20
720720 fully to execute the office of President of the United States 21
721721 and, to the best of his ability, preserve, protect, and defend 22
722722 the Constitution of the United States, and in violation of 23
723723 his constitutional duty to take care that the laws be faith-24
724724 fully executed—Donald John Trump has abused the pow-25
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728728 ers of the Presidency in a manner offensive to, and subver-1
729729 sive of, the Constitution, in that: 2
730730 He has, by his actions and statements, sought to es-3
731731 tablish himself as tyrant, dictator, and autocrat over the 4
732732 People of the United States, usurping unto himself the 5
733733 constitutional powers of Congress, the courts, and the 6
734734 States, and powers illegitimate and beyond the scope of 7
735735 lawful government altogether. 8
736736 He has claimed for himself absolute and arbitrary 9
737737 power, the ability to suspend laws at whim, and utterly 10
738738 disregarded and betrayed his oath to faithfully execute the 11
739739 office of President of the United States and to preserve, 12
740740 protect, and defend the Constitution of the United States. 13
741741 He has denied and violated the right of the People 14
742742 of the United States to freedom of speech, and of assem-15
743743 bly, and to petition the government for redress of griev-16
744744 ances. 17
745745 He has denied and violated the right of the People 18
746746 of the United States to due process of law and equal pro-19
747747 tection under the laws, to fair and impartial independent 20
748748 courts, and to legal counsel. 21
749749 He has sought to intimidate and coerce, by means 22
750750 including the threat of unlawful prosecutions and by en-23
751751 couraging violence and threats of violence, the Representa-24
752752 tives and Senators in Congress. 25
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756756 He has denied and violated the separation of powers 1
757757 and the Constitution’s system of checks and balances, ar-2
758758 rogating unto himself the legislative and judicial powers, 3
759759 including the power of Congress to levy taxes, appropriate 4
760760 public funds, direct the organization of officers and agen-5
761761 cies of the executive branch, and to make laws. 6
762762 He has sought to intimidate, coerce, and extort the 7
763763 officers of the several States, including those elected by 8
764764 the People thereof, and thereby sought to commandeer the 9
765765 several States, in violation of their sovereignty and the 10
766766 system of federalism established by the Constitution of the 11
767767 United States. 12
768768 He has sought to abrogate the citizenship clause of 13
769769 the 14th Amendment to the Constitution, by means in-14
770770 cluding the issuance of an executive order that directs ex-15
771771 ecutive departments and agencies to withhold citizenship 16
772772 from certain classes of persons who are born within the 17
773773 United States. 18
774774 He has repeatedly threatened and suggested that he 19
775775 intends to violate the Presidential term limits established 20
776776 by the 22d Amendment to the Constitution, and adopted 21
777777 overtly monarchical aspirations and affectations, including 22
778778 by invoking and endorsing theories that he is above the 23
779779 law or that his personal will constitutes the law. 24
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783783 In all of this, Donald John Trump has willfully dis-1
784784 regarded Federal laws and the Constitution, imperiled a 2
785785 coequal branch of Government, and threatened the integ-3
786786 rity of the democratic system. He thereby betrayed his 4
787787 trust as President, abused the powers of the Presidency, 5
788788 acted in a manner grossly incompatible with self-govern-6
789789 ance and the rule of law, and has committed High Crimes 7
790790 and Misdemeanors in attempting to establish himself as 8
791791 a lawless tyrant to the manifest injury of the people of 9
792792 the United States. 10
793793 Wherefore, Donald John Trump, by such conduct, 11
794794 has demonstrated that he is unfit to govern a Nation by 12
795795 and for the people, has acted in a manner grossly incom-13
796796 patible with self-governance and the rule of law, and will 14
797797 remain a threat to the Constitution if allowed to remain 15
798798 in office. 16
799799 Æ
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