IV 

115TH CONGRESS 

1ST SESSION H. RES. 621 

Impeaching Donald J. Trump, President of the United States, of high crimes 

and misdemeanors. 

IN THE HOUSE OF REPRESENTATIVES 

NOVEMBER 15, 2017 

Mr. COHEN (for himself, Mr. GUTIE ́RREZ, Mr. YARMUTH, Mr. AL GREEN of 

Texas, Ms. FUDGE, and Mr. ESPAILLAT) submitted the following resolution; which was referred to the Committee on the Judiciary 

RESOLUTION 

Impeaching Donald J. Trump, President of the United 

States, of high crimes and misdemeanors. 

1 Resolved, That Donald J. Trump, President of the 

2 United States, is impeached for high crimes and mis3 demeanors, and that the following Articles of Impeach4 ment be exhibited to the Senate: 

5 Articles of Impeachment exhibited by the House of 

6 Representatives of the United States of America in the 

7 name of itself and all of the people of the United States 

8 of America, against Donald J. Trump, President of the 

9 United States, in maintenance and support of its impeach10 ment against him for high crimes and misdemeanors. 


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1 ARTICLE I

2 OBSTRUCTION OF JUSTICE

3 In his conduct while President of the United States, 

4 Donald J. Trump, in violation of his constitutional oath 

5 to faithfully execute the office of President of the United 

6 States and, to the best of his ability, preserve, protect, 

7 and defend the Constitution of the United States, as well 

8 as his constitutional obligation to take care that the laws 

9 be faithfully executed, has prevented, obstructed, and im10 peded the administration of justice, and has to that end 

11 engaged personally, and through his subordinates and 

12 agents, in a course of conduct or scheme designed to delay, 

13 impede an investigation, and to conceal information 

14 sought by the Federal Bureau of Investigation (FBI) in 

15 the course of its investigation into Russian interference 

16 with the 2016 United States Presidential election, includ17 ing any possible collusion between Russia and Donald J. 

18 Trump’s campaign. 

19 The means used to implement this course of conduct 

20 or scheme included one or more of the following acts: 

21 On November 17, 2016, President-elect Trump des22 ignated Retired General Michael Flynn to serve as Na23 tional Security Advisor. 

24 On December 25, 2016, Retired General Michael 

25 Flynn communicated with Russian Ambassador to the 

26 United States Sergey Kislyak. 


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1 On December 29, 2016, the same day that President 

2 Barack Obama announced sanctions against Russian enti3 ties and the expulsion of suspected Russian intelligence 

4 operatives from the United States, Retired General Flynn 

5 spoke again with Russian Ambassador Kislyak. 

6 On January 15, 2017, in response to questions about 

7 Retired General Flynn’s communications with Russian of8 ficials during the Presidential transition, Vice President9 elect Mike Pence said that Retired General Flynn and Am10 bassador Kislyak, ‘‘. . . did not discuss anything having 

11 to do with the United States’ decision to expel diplomats 

12 or impose censure against Russia.’’. 

13 On January 23, 2017, White House Press Secretary 

14 Sean Spicer reiterated that National Security Advisor 

15 Flynn and Ambassador Kislyak had only discussed holiday 

16 greetings, a December plane crash, a conference in Syria 

17 on ISIS and setting up a call between President Putin 

18 and Donald J. Trump. 

19 On January 26, 2017, Acting Attorney General Sally 

20 Yates warned White House Counsel Don McGahn that 

21 National Security Advisor Flynn had misled Vice Presi22 dent Pence about his communications with Ambassador 

23 Kislyak, and that, as a result, Flynn was at risk for being 

24 blackmailed by the Russians. 


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1 Flynn was asked to resign from the Trump adminis2 tration on February 13, 2017. 

3 On January 27, 2017, Donald J. Trump invited FBI 

4 Director James Comey to a one-on-one dinner at the 

5 White House, during which he demanded Director 

6 Comey’s loyalty. 

7 On February 14, 2017, at the conclusion of an Oval 

8 Office meeting on counterterrorism attended by the Vice 

9 President, the Deputy Director of the CIA, the Director 

10 of the National Counter-Terrorism Center, the Secretary 

11 of Homeland Security, the Attorney General and the Di12 rector of the FBI, Donald J. Trump requested that every13 one leave the room so he could speak with FBI Director 

14 Comey alone. Once alone, Donald J. Trump told Director 

15 Comey, ‘‘I hope you can see your way clear to letting this 

16 go, to letting Flynn go,’’ and, ‘‘he is a good guy. I hope 

17 you can let this go.’’. 

18 On March 20, 2017, Director James Comey testified 

19 before Congress that the FBI was investigating Russian 

20 interference with the 2016 U.S. Presidential election, in21 cluding the possibility of its collusion with the Trump cam22 paign. 

23 On March 30, 2017, Donald J. Trump called FBI 

24 Director James Comey and said the Russia investigation 


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1 was, ‘‘a cloud,’’ that was impairing his ability to act on 

2 behalf of the country. 

3 On May 9, 2017, while the FBI was investigating 

4 whether there was any collusion between the Trump cam5 paign and Russia, Donald J. Trump fired FBI Director 

6 James Comey. In his letter informing Director Comey that 

7 he was being terminated, Donald J. Trump said, ‘‘While 

8 I greatly appreciate you informing me, on three separate 

9 occasions, that I am not under investigation, I neverthe10 less concur with the judgment of the Department of Jus11 tice that you are not able to effectively lead the Bureau.’’. 

12 According to the New York Times, on May 10, 2017, 

13 Donald J. Trump told Russian Foreign Minister Sergey 

14 Lavrov and Russian Ambassador to the United States 

15 Sergey Kislyak, ‘‘I just fired the head of the F.B.I. He 

16 was crazy, a real nut job . . . I faced great pressure be17 cause of Russia. That’s taken off.’’. 

18 On May 17, 2017, the U.S. Department of Justice 

19 appointed former FBI Director Robert Mueller to serve 

20 as a special counsel to investigate links between the Rus21 sian government and Donald J. Trump’s Presidential 

22 campaign. 

23 According to the New York Times, shortly after 

24 learning that a special counsel had been appointed, Donald 

25 J. Trump berated Attorney General Jeff Sessions in an 


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1 Oval Office meeting, said Sessions should resign, and ac2 cused Sessions of ‘‘disloyalty’’. According to the New York 

3 Times, Sessions told Donald J. Trump he would quit and 

4 sent a resignation letter to the White House. According 

5 to the New York Times, Donald J. Trump rejected Ses6 sions’ resignation letter after senior members of his ad7 ministration argued that dismissing the attorney general 

8 would only create more problems. 

9 On May 12, 2017, while speaking in a nationally tele10 vised interview about his decision to fire Director Comey, 

11 Donald J. Trump said, ‘‘And in fact when I decided to 

12 just do it, I said to myself, I said you know, this Russia 

13 thing with Trump and Russia is a made up story, it’s an 

14 excuse by the Democrats for having lost an election that 

15 they should have won.’’. 

16 According to the Washington Post, on July 8, 2017, 

17 Donald J. Trump personally dictated a statement for his 

18 son and former Trump campaign operative, Donald 

19 Trump, Jr., to use to explain Donald Trump, Jr.’s, meet20 ing during the 2016 Presidential campaign with Russian 

21 lawyer Natalia Veselnitskaya. In the statement, Donald 

22 Trump, Jr., said he and Veselnitskaya had, ‘‘primarily dis23 cussed a program about the adoption of Russian chil24 dren,’’ and that the subject of the meeting was, ‘‘not a 

25 campaign issue at the time’’. 


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1 Donald Trump, Jr., later released emails showing 

2 that he had accepted the meeting with Veselnitskaya in 

3 response to an email offering to provide damaging infor4 mation about Hillary Clinton as a part of a Russian gov5 ernment effort to help his father’s campaign. Specifically, 

6 a June 3, 2017, email to Trump, Jr., stated, ‘‘The Crown 

7 prosecutor of Russia met with his father Aras this morn8 ing and in their meeting offered to provide the Trump 

9 campaign with some official documents and information 

10 that would incriminate Hillary and her dealings with Rus11 sia and would be very useful to your father. This is obvi12 ously very high level and sensitive information but is part 

13 of Russia and its government’s support for Mr. Trump 

14 . . .’’. 

15 In all of this, Donald J. Trump has obstructed the 

16 administration of justice. In so doing he has undermined 

17 the integrity of his office, brought disrepute on the Presi18 dency, and betrayed his trust as President in a manner 

19 subversive of constitutional government, to the great prej20 udice of the cause of law and justice and to the manifest 

21 injury of the people of the United States. 

22 Wherefore Donald J. Trump, by such conduct, war23 rants impeachment and trial, and removal from office. 


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1 ARTICLE II

2 VIOLATION OF THE FOREIGN EMOLUMENTS CLAUSE—AR3 TICLE I, SECTION 9 OF THE UNITED STATES CON4 STITUTION

5 In his conduct while President of the United States, 

6 Donald J. Trump, in violation of his constitutional oath 

7 to faithfully execute the office of President of the United 

8 States and, to the best of his ability, preserve, protect, 

9 and defend the Constitution of the United States, as well 

10 as his constitutional obligation to take care that the laws 

11 be faithfully executed, accepted, without the consent of 

12 Congress emoluments from foreign states in the following 

13 manner: 

14 Donald J. Trump refused to divest, place into a blind 

15 trust, or otherwise give up his ownership interest in his 

16 worldwide business holdings since becoming President. 

17 Donald J. Trump refused to release his tax returns, 

18 with the intent to conceal the exact nature of his holdings 

19 from Congress and the American people. 

20 Donald J. Trump acknowledged, through his personal 

21 attorney, that his businesses receive funds and make a 

22 profit from payments by foreign governments, and would 

23 continue to do so while serving as President. 


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1 FOREIGN PAYMENTS DERIVED FROM REAL ESTATE

2 HOLDINGS

3 Donald J. Trump owns approximately 77 percent of 

4 Trump International Hotel in Washington, DC, which 

5 holds a lease from the General Services Administration. 

6 The Trump International Hotel in Washington, DC, 

7 has actively courted foreign diplomats for their business, 

8 and according to public reports, since the November 2016 

9 Presidential election, diplomats have made plans to stay 

10 at the hotel to curry favor with Donald J. Trump and 

11 some diplomats have said spending money at Trump’s 

12 hotel is an easy, friendly gesture to the new President. 

13 The Embassy of Kuwait canceled a ‘‘save the date’’ 

14 reservation for an event at the Four Seasons Hotel in 

15 Washington, DC, and held its National Day Celebration, 

16 instead, at Trump International Hotel in Washington, 

17 DC, on February 22, 2017. According to Reuters, similar 

18 events for a crowd of several hundred at the Trump Inter19 national Hotel can run from $40,000 to $60,000. 

20 On or about April 6, 2017, the Ambassador & Perma21 nent Representative of Georgia to the United Nations 

22 tweeted, ‘‘Trump International Hotel Washington DC 

23 @TrumpDC – great #hotel and so far the best service 

24 I’ve seen in the United States! Keep it up! #travel’’. 


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1 According to the Washington Post, in May 2017, 

2 business groups promoting Turkish American relations 

3 held an annual convention at the Trump International 

4 Hotel in Washington, DC. The Turkish ambassador and 

5 a high-ranking official from the U.S. Department of State 

6 attended. The convention included a $95 per person din7 ner for 190 guests. On May 23, 2017, breakfast, dinner 

8 and drinks ran more than $30,000, including a ‘‘Banquet 

9 Event Service Charge’’ of 24 percent. 

10 According to the Washington Post, from May 11, 

11 2017, to May 13, 2017, an Italian medical foundation 

12 hosted doctors from the University of Texas and the Uni13 versity Medical Center in Hamburg at the Trump Inter14 national Hotel in Washington, DC. 

15 According to the Washington Post, in September 

16 2017, Malaysian Prime Minister Najib Razak’s visit to the 

17 White House was accompanied by at least 24 hours of ac18 tivity and sales to the Trump International Hotel in 

19 Washington, DC. On September 11, 2017, more than a 

20 dozen members of Najib’s entourage were seen in a lounge 

21 area for hotel guests. On September 12, 2017, dozens of 

22 delegation members met in meeting rooms with name 

23 cards bearing the Malaysian coat of arms and some at24 tended a breakfast in the hotel’s Lincoln Library meeting 

25 room. According to the Washington Post, events of this 


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1 scale probably generated hundreds of thousands of dollars 

2 in revenue for the Trump Organization, based on con3 firmed spending totals of other groups. 

4 According to the Washington Post, the Kingdom of 

5 Saudi Arabia paid the Trump International Hotel in 

6 Washington, DC, $270,000 in hotel charges, including 

7 about $190,000 for rooms, $78,000 for catering and 

8 $1,600 for parking as part of an effort to bring veterans 

9 groups to Washington, DC, to lobby Congress against a 

10 law allowing victims of the September 11, 2001, attacks 

11 to sue Saudi Arabia. 

12 Donald J. Trump did not first seek or obtain the con13 sent of Congress before accepting any of the benefits from 

14 foreign states derived from their patronage of the Trump 

15 International Hotel in Washington, DC. 

16 Donald J. Trump owns Trump Tower, a mixed-use 

17 skyscraper in New York City. At least two tenants of 

18 Trump Tower are entities owned by foreign states: (1) the 

19 Industrial and Commercial Bank of China, which is owned 

20 by China, and (2) Abu Dhabi Tourism & Culture Author21 ity, which is owned by the United Arab Emirates. 

22 Donald J. Trump did not first seek or obtain the con23 sent of Congress before accepting any of the benefits from 

24 foreign states derived from their patronage of the Trump 

25 Tower in New York City. 


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1 Donald J. Trump also owns Trump World Tower in 

2 New York City. 

3 In 2001, the Kingdom of Saudi Arabia purchased a 

4 floor of Trump World Tower, and the floor currently be5 longs to the Saudi Mission to the United Nations. At the 

6 time of the sale, the floor had yearly common charges of 

7 $85,585 for building amenities. 

8 Donald J. Trump has likely accepted common 

9 charges from the Kingdom of Saudi Arabia for its use of 

10 Trump World Tower. 

11 Donald J. Trump did not first seek or obtain the con12 sent of Congress before accepting benefits from Saudi 

13 Arabia due to its use of Trump World Tower in New York 

14 City. 

15 FOREIGN REGULATORY BENEFITS

16 In November 2016, when Argentine President 

17 Mauricio Macri called Donald J. Trump to congratulate 

18 him on his victory, the President reportedly asked him to 

19 deal with the permitting issues that were delaying an of20 fice building project in Buenos Aires, Argentina, that 

21 Donald J. Trump and Argentine partners had been work22 ing on for a number of years. Three days after Trump 

23 spoke with Argentina’s President, the long-delayed project 

24 moved ahead. 

25 Shortly after Donald J. Trump’s Presidential election 

26 victory, a news agency in the country of Georgia reported 


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1 that a long-stalled plan for a Trump-branded tower in a 

2 seaside Georgian resort town was back on track to move 

3 ahead. 

4 Donald J. Trump did not first seek or obtain the con5 sent of Congress before accepting regulatory benefits from 

6 Argentina or the country of Georgia. 

7 DONATIONS TO U.S. TREASURY

8 On January 11, 2017, Donald J. Trump held a press 

9 conference at which his attorney Sheri Dillon announced 

10 that Donald J. Trump would donate hotel profits gen11 erated by foreign government payments to the Treasury 

12 of the United States. 

13 On April 21, 2017, House Committee on Oversight 

14 and Government Reform Chairman Jason Chaffetz and 

15 Ranking Member Elijah Cummings requested documents 

16 and information from Ms. Dillon regarding how and when 

17 funds would be remunerated to the Treasury of the United 

18 States. The letter specifically requested details as to how 

19 payments from foreign governments or foreign-owned enti20 ties are being identified by the Trump Organization and 

21 whether the Trump Organization, Donald J. Trump, or 

22 his trust planned to claim donations to the Treasury of 

23 the United States as a gift for tax deduction purposes. 

24 In response to the committee’s request, the Trump 

25 Organization produced a pamphlet stating, ‘‘To fully and 

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1 tomer type is impractical in the service industry and put2 ting forth a policy that requires all guests to identify 

3 themselves would impede upon the personal privacy and 

4 diminish the guest experience of our brand. It is not the 

5 intention nor design of this policy for our Properties to 

6 attempt to identify individual travelers who have not spe7 cifically identified themselves as being a representative of 

8 a foreign government entity on foreign government busi9 ness.’’. 

10 With regard to whether the Trump Organization, 

11 Donald J. Trump, or his trust plans to claim donations 

12 to the Treasury of the United States as a gift for tax de13 duction purposes, the Trump Organization responded, 

14 ‘‘. . . we believe it is premature to respond at this time 

15 insofar as final determinations regarding these matters 

16 are dependent on many factors that will not be known to 

17 TTO [The Trump Organization] until after the close of 

18 this year.’’. 

19 By accepting emoluments from foreign governments 

20 without first seeking and obtaining the consent of Con21 gress, Donald J. Trump left himself open to foreign influ22 ence and deprived the American people of the assurance 

23 that their highest elected official was working on their be24 half with undivided loyalty, and violated article I, section 

25 9 of the U.S. Constitution. 


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1 In all of this, Donald J. Trump has undermined the 

2 integrity of his office, brought disrepute on the Presi3 dency, and betrayed his trust as President in a manner 

4 subversive of constitutional government, against the cause 

5 of law and justice and to the manifest injury of the people 

6 of the United States. 

7 Wherefore Donald J. Trump, by such conduct, war8 rants impeachment and trial, and removal from office. 

9 ARTICLE III

10 VIOLATION OF THE DOMESTIC EMOLUMENTS CLAUSE— 

11 ARTICLE II, SECTION 1 OF THE UNITED STATES

12 CONSTITUTION

13 In his conduct while President of the United States, 

14 Donald J. Trump, in violation of his constitutional oath 

15 to faithfully execute the office of President of the United 

16 States and, to the best of his ability, preserve, protect, 

17 and defend the Constitution of the United States, as well 

18 as his constitutional obligation to take care that the laws 

19 be faithfully executed, accepted, emoluments from the 

20 United States in the following manner: 

21 Donald J. Trump refused to divest, place into a blind 

22 trust, or otherwise give up his ownership interest in his 

23 worldwide business holdings since becoming President. 

24 Donald J. Trump refused to release his tax returns, 

25 with the intent to conceal the exact nature of his holdings 

26 from Congress and the American people. 


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1 Donald J. Trump has an ownership interest in the 

2 Mar-a-Lago Club in Palm Beach, Florida. 

3 Donald J. Trump has an ownership interest in the 

4 Trump National Golf Club in Bedminster, New Jersey. 

5 Since becoming President, Donald J. Trump has vis6 ited Mar-a-Lago in Palm Beach, Florida, at least seven 

7 times, and has visited the Trump National Golf Club in 

8 Bedminster, New Jersey, at least five times. 

9 Since becoming President, Donald J. Trump has vis10 ited other Trump-branded properties including the Trump 

11 National Golf Club in Jupiter, Florida, the Trump Na12 tional Golf Club in Sterling, Virginia. 

13 According to the New York Times, as of September 

14 25, 2017, Donald J. Trump had visited at least one 

15 Trump-branded property on 85 days of his Presidency, as 

16 compared to 164 days in which he did not visit a Trump17 branded property. 

18 Donald J. Trump caused the United States Govern19 ment to spend Federal funds at Trump-branded properties 

20 in which he has an ownership interest, including a re21 ported $73,000 by the Secret Service on golf cart rentals, 

22 as well as $1,092 by the National Security Council for 

23 two nights of lodging at Mar-a-Lago. 

24 By accepting emoluments from the United States in 

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1 nesses in which Donald J. Trump has an ownership inter2 est, Donald J. Trump violated article II, section 1 of the 

3 U.S. Constitution. 

4 In all of this, Donald J. Trump has undermined the 

5 integrity of his office, brought disrepute on the Presi6 dency, and betrayed his trust as President in a manner 

7 subversive of constitutional government, against the cause 

8 of law and justice and to the manifest injury of the people 

9 of the United States. 

10 Wherefore Donald J. Trump, by such conduct, war11 rants impeachment and trial, and removal from office. 

12 ARTICLE IV

13 ABUSE OF POWER—UNDERMINING THE INDEPENDENCE

14 OF THE FEDERAL JUDICIARY AND THE RULE OF LAW

15 In his conduct while President of the United States, 

16 Donald J. Trump, in violation of his constitutional oath 

17 to faithfully execute the office of the President of the 

18 United States and, to the best of his ability, preserve, pro19 tect, and defend the Constitution of the United States, 

20 as well as his constitutional obligation to take care that 

21 the laws be faithfully executed, has engaged in activities 

22 that undermine the independence of the Federal judiciary. 

23 On January 27, 2017, Donald J. Trump signed an 

24 Executive order banning entry for 90 days by citizens 

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1 torn Syria, and stopping admission of all refugees to the 

2 United States for four months. The order stated that upon 

3 resumption of admission of refugees to the United States, 

4 prioritization would be given to refugee claims made by 

5 individuals on the basis of religious-based persecution, 

6 provided that the religion of the individual is a minority 

7 religion in the individual’s country of nationality. 

8 On February 3, 2017, U.S. District Court Judge 

9 James Robart issued a nationwide restraining order tem10 porarily blocking the Executive order issued by Donald J. 

11 Trump on January 27, 2017. 

12 On February 4, 2017, Donald J. Trump tweeted, 

13 ‘‘The opinion of this so-called judge, which essentially 

14 takes law-enforcement away from our country, is ridicu15 lous and will be overturned!’’. 

16 U.S. District Court Judge James Robart was nomi17 nated by President George W. Bush in 2003, and con18 firmed by the U.S. Senate in June 2004 by a vote of 99– 

19 0. 

20 Donald J. Trump’s tweet about Judge Robart was 

21 consistent with a lack of respect for the Federal judiciary 

22 Donald J. Trump displayed as a candidate for President. 

23 On February 27, 2016, Donald J. Trump accused U.S. 

24 District Court Judge Gonzalo P. Curiel of being biased 

25 against him in overseeing a class action lawsuit against 


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1 Trump University, saying, ‘‘We have a very hostile judge 

2 because, to be honest with you, the judge should’ve thrown 

3 the case out on summary judgment. But because it was 

4 me and because there’s a hostility toward me by the judge, 

5 tremendous hostility, beyond belief. I believe he happens 

6 to be Spanish, which is fine. He is Hispanic, which is fine. 

7 And we haven’t asked for recusal, which we may do. But 

8 we have a judge who is very hostile.’’. 

9 On February 28, 2016, Donald J. Trump said, ‘‘I 

10 think the judge has been extremely hostile to me. I think 

11 it has to do with perhaps the fact that I’m very, very 

12 strong on the border. Very, very strong on the border. And 

13 he has been extremely hostile to me. This is a case that 

14 in our opinion should have been won a long time ago. It’s 

15 a case that we should have won on summary judgment 

16 . . . we have a very hostile judge. Now, he is Hispanic, 

17 I believe. He is a very hostile judge to me. I said it loud 

18 and clear.’’. 

19 On May 27, 2016, Donald J. Trump said, ‘‘Every20 body says it, but I have a judge who is a hater of Donald 

21 Trump, a hater. He’s a hater. His name is Gonzalo Curiel 

22 and he is not doing the right thing . . . So what happens 

23 is the judge, who happens to be, we believe, Mexican, 

24 which is great. I think that’s fine. You know what? I think 

25 the Mexicans are going to end up loving Donald Trump 


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1 when I give all these jobs, OK? I think they’re going to 

2 end up . . . I think they’re going to love me . . . So I’ll 

3 be seeing you in November either as president—and I will 

4 say this . . . I think Judge Curiel should be ashamed of 

5 himself. I think it’s a disgrace that he’s doing this . . . 

6 I will tell you, this court system—the judges in this court 

7 system, federal court. They ought to look into that Judge 

8 Curiel because what Judge Curiel is doing is a total dis9 grace. OK? But we’ll come back in November. Wouldn’t 

10 that be wild if I’m president and I come back to do a 

11 civil case?’’. 

12 On June 3, 2016, Donald J. Trump said, ‘‘Look, he’s 

13 proud of his heritage, OK? I’m building a wall. Now, I 

14 think I’m going to do very well with Hispanics . . . be15 cause I’m going to bring back jobs. And they are going 

16 to get jobs. I think I’m going to do very well with His17 panics. But we are building a wall. He’s a Mexican. We’re 

18 building a wall between here and Mexico. The answer is, 

19 he is giving us very unfair rulings, rulings that people 

20 can’t even believe. This case should have ended years ago 

21 on summary judgment. The best lawyers—I have spoken 

22 to so many lawyers—they said, ‘This is not a case. This 

23 is a case that should have ended.’. This judge is giving 

24 us unfair rulings. Now, I say. ‘Why?’ Well, I’m building 


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1 a wall, OK? And it’s a wall between Mexico. Not another 

2 country.’’. 

3 U.S. District Court Judge Gonzalo P. Curiel was 

4 born in Indiana and was appointed to the California Supe5 rior Court by Governor Arnold Schwarzenegger in 2006. 

6 Judge Curiel was nominated to the Federal bench by 

7 President Barack Obama in 2011 and confirmed by the 

8 U.S. Senate in 2012 by voice vote. 

9 In 2011, as a part of a lawsuit alleging that the Mari10 copa County, Arizona, Sheriff’s Office was racially 

11 profiling Latinos, detaining them based solely on the sus12 picion that they were in the country illegally, and turning 

13 them over to immigration authorities, U.S. District Court 

14 Judge Murray Snow ordered Maricopa County Sheriff Joe 

15 Arpaio to stop detentions based solely on an individual’s 

16 immigration status, when there was no evidence that a 

17 State law had been broken. 

18 On July 31, 2017, U.S. District Court Judge Susan 

19 Bolton ruled that Joe Arpaio had willfully violated the 

20 2011 court order, and held Joe Arpaio in criminal con21 tempt of court. 

22 On August 25, 2017, before Joe Arpaio had been sen23 tenced, or his conviction had been appealed, and without 

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1 doned Joe Arpaio for his commission of criminal contempt 

2 of court. 

3 In all of this, Donald J. Trump has sought to under4 mine the independence of the Federal judiciary and the 

5 rule of law, repeatedly attempted to upset the careful con6 stitutional balance of power between the judicial and exec7 utive branches. By pardoning Joe Arpaio’s willful violation 

8 of a Federal court order, Donald J. Trump has offered 

9 encouragement to others to disobey Federal court orders 

10 with which Donald J. Trump may disagree. He has 

11 brought disrepute on the Presidency, and has acted in a 

12 manner subversive of constitutional government, to the 

13 great prejudice of the cause of law and justice and to the 

14 manifest injury of the people of the United States. 

15 Wherefore Donald J. Trump, by such conduct, war16 rants impeachment and trial, and removal from office. 

17 ARTICLE V

18 UNDERMINING FREEDOM OF THE PRESS

19 In his conduct while President of the United States, 

20 Donald J. Trump, in violation of his constitutional oath 

21 to faithfully execute the office of the President of the 

22 United States and, to the best of his ability, preserve, pro23 tect, and defend the Constitution of the United States, 

24 as well as his constitutional obligation to take care that 

25 the laws be faithfully executed, has engaged in activities 


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•HRES 621 IH 

1 that undermine the freedom of the press guaranteed by 

2 the First Amendment to the Constitution. 

3 Donald J. Trump repeatedly called press organiza4 tions ‘‘fake news’’ including, on February 15, 2017, when 

5 he tweeted, ‘‘The fake news media is going crazy with 

6 their conspiracy theories and blind hatred. @MSNBC & 

7 @CNN are unwatchable. @foxandfriends is great!’’. 

8 On February 17, 2017, Donald J. Trump tweeted, 

9 ‘‘The FAKE NEWS media (failing @nytimes, 

10 @NBCNews, @ABC, @CBS, @CNN) is not my enemy, 

11 it is the enemy of the American People!’’. 

12 Donald J. Trump has repeatedly attacked members 

13 of the press, including as a candidate on August 7, 2015, 

14 when he commented about Fox News Channel anchor and 

15 Presidential debate moderator Megyn Kelly saying, ‘‘you 

16 could see there was blood coming out of her eyes, blood 

17 coming out of her whatever’’. 

18 On June 29, 2017, Donald J. Trump tweeted, ‘‘I 

19 heard poorly rated Morning Joe speaks badly of me (don’t 

20 watch anymore). Then how come low I.Q. Crazy Mika, 

21 along with Psycho Joe, came to Mar-a-Lago 3 nights in 

22 a row around New Year’s Eve, and insisted on joining me. 

23 She was badly bleeding from a face-lift. I said no!’’. 

24 On July 2, 2017, Donald J. Trump tweeted 

25 ‘‘#FraudNewsCNN#FNN’’ and circulated a video of him 


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•HRES 621 IH 

1 violently wrestling a man covered by a CNN logo, which, 

2 according to the Reporters Committee on Freedom of the 

3 Press, was a ‘‘threat of physical violence against journal4 ists . . . [and] beneath the office of the presidency’’. 

5 On May 10, 2017, Donald J. Trump’s White House 

6 barred American reporters from witnessing his meeting 

7 with Russian Foreign Minister Sergey Lavrov and Russian 

8 Ambassador to the United States Sergey Kislyak in the 

9 Oval Office, but allowed a Russian photographer to docu10 ment the meeting. 

11 In January 2017, Donald J. Trump’s transition team 

12 considered a plan to relocate the press corps from the 

13 White House press room to the White House Conference 

14 Center near Lafayette Square or to space in the Old Exec15 utive Office Building. 

16 In June 2017, Donald J. Trump’s administration 

17 prohibited video recordings of White House press brief18 ings. 

19 On October 11, 2017, Donald J. Trump tweeted, 

20 ‘‘Fake @NBC News made up story that I wanted a ‘ten21 fold’ increase in our U.S. nuclear arsenal. Pure fiction, 

22 made up to demean. NBC=CNN!’’ and ‘‘With all of the 

23 Fake News coming out of NBC and the Networks at what 

24 point is it appropriate to challenge their License? Bad for 

25 country!’’. 


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•HRES 621 IH 

1 On October 11, 2017, Donald J. Trump also tweeted, 

2 ‘‘Network news has become so partisan, distorted and fake 

3 that licenses must be challenged and, if appropriate, re4 voked. Not fair to public!’’. 

5 On October 11, 2017, Donald J. Trump told report6 ers in the Oval Office, ‘‘It is frankly disgusting the way 

7 the press is able to write whatever they want to write, and 

8 people should look into it.’’. 

9 In all of this, Donald J. Trump has sought to under10 mine the freedom of the press guaranteed by the First 

11 Amendment to the Constitution, brought disrepute on the 

12 Presidency, and has acted in a manner subversive of con13 stitutional government, to the great prejudice of the cause 

14 of law and justice and to the manifest injury of the people 

15 of the United States. 

16 Wherefore Donald J. Trump, by such conduct, war17 rants impeachment and trial, and removal from office. 

Æ 


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