CASE ANALYSIS: Willian Jefferson vs.

Paula Corbin Jones

 SUPREME COURT OF THE UNITED STATES

No. 95-1853

WILLIAM JEFFERSON CLINTON (Defendant) v. PAULA CORBIN JONES (Plaintiff)

ON WRIT OF CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE EIGHTH

CIRCUIT

Facts

William Jefferson Clinton was 42nd President of the United States from 1993 to 2001

and Governor of Arkansas from 1979 to 1992. In 1991, Clinton attended an official conference

held at a hotel in Arkansas where Paula Corbin Jones worked as a state employee at the

registration desk. She alleges that Danny Ferguson, a former Arkansas State Police Officer

persuaded her to visit Clinton in a business suite at the hotel, where he made sexual advances

that she rejected. She further claims that her superiors at work subsequently dealt with her in a

hostile manner and changed her duties to punish her for rejecting Clinton’s advances. Finally,

she alleges that after Clinton was elected President, Ferguson defamed her by making a

statement to a reporter that implied she had accepted Clinton's alleged overtures, and that various

persons authorized to speak for the President publicly branded her a liar by denying that the

incident had occurred. She filed suit in the District Court for the Eastern District of Arkansas,

naming Clinton and Ferguson as defendants. Jones sought actual damages of $75,000 and

punitive damages of $100,000. Clinton sought to dismiss the claim on the ground of presidential

immunity, or, alternatively, to delay the proceedings until his term of office had expired.

Following a District Court's grant of Clinton's request that all matters relating to the suit be
suspended, pending a ruling on his prior request to have the suit dismissed on grounds of

presidential immunity, Clinton sought to invoke his immunity to completely dismiss the Jones

suit against him. While the District Judge denied Clinton's immunity request, the judge ordered

the stay of any trial in the matter until after Clinton's Presidency. On appeal, the Eighth Circuit

affirmed the dismissal denial but reversed the trial deferment ruling since it would be a

"functional equivalent" to an unlawful grant of temporary presidential immunity.

Procedure

The district court was the first court to hear the case and the court denied the motion to

dismiss and ordered discovery to proceed, but it also ordered that the trial be stayed until the end

of Clinton’s term. Both parties appealed. A divided panel of the Court of Appeals affirmed the

denial of the motion to dismiss, but because it regarded the order postponing the trial until the

President leaves office as the "functional equivalent" of a grant of temporary immunity, it

reversed that order. President Clinton appealed to the U.S. Supreme Court.

Issues

Justice Stevens heard the case and summarized his findings that there have been three

sitting presidents thus far that have been defendants in a civil cases against them The principal

rationale for affording certain public servants immunity from suits for money damages arising

out of their official acts is inapplicable to unofficial conduct. That rationale provided the

principal basis for our holding that a former president of the United States was “entitled to

absolute immunity from damages liability predicated on his official acts.” Our central concern

was to avoid rendering the President “unduly cautious in the discharge of his official duties. This
immunity does not refer to unofficial conduct of the president. There must be a justified purpose

to put the trial off until after the president is done with their term. Unfortunately, the district

courts tried to enforce that ruling of immunity, but they do not apply to the official’s private

actions outside of the office of duty.

Explain the applicable law

Separation of power

Separation of Power is “Constitutional doctrine whereby the legislative branch enacts

laws and appropriates funds, the executive branch sees that the laws are faithfully executed, and

the judicial branch interprets the laws” (Kubasek, Brennan, & Browne, 107)

The checks and balance system is part of the three branches of government but with the

separation there comes times where there are extreme hindrances to what a particular branch is

trying to achieve. The judiciary branch “may severely burden the executive branch by reviewing

the legality of the president’s official conduct, and if it may direct appropriate process to the

President himself, if must follow that the federal courts have power to determine the legality of

his unofficial conduct (Kubasek, Brennan, & Browne, 107)

In this case unofficial conduct of the President needed to be reviewed because of the civil

action lawsuit.
 Holding

The Supreme Court reviewed the case and came to the same conclusion as appeals court. The

court decision to reject the immunity claim and allowing the case to proceed.

Reasoning

The President is subject to private law suit for conduct prior to entering the office. The

President, moreover, may not defer the litigation until after the office term expires. The court

believes there is no precedent which supports a deferral of the lawsuit and clearly the President

cannot shed private litigation upon entering the office. A deferral of the suit would be unfairly

lengthy and violate the private citizen’s right to a speedy and fair trial. The court makes clear

that there is no immunity for the President’s “unofficial” conduct at any point during this

tenure. Executive immunity can be claimed to protect national security or the public interest,

the court may do so; but when the issue is clearly a private matter, especially occurring prior his

tenure in office, the immunity cannot rightly be sustained.

References

Kubasek, N. K., Brennan, B. A., & Browne, M. N. (2017). The legal environment of business: A critical

thinking approach. Boston: Pearson.

S. (1997, May 27). Clinton v. Jones, 520 U.S. 681 (1997). Retrieved from

https://www.law.cornell.edu/supct/html/95-1853.ZO.html