Article I: Obstruction of Justice, Violation of Due Process, and a Breach of the Duty to Faithfully Execute Laws

The Constitution provides that the House of Representatives shall have the sole Power of Impeachment and that the President shall be removed from Office on Impeachment for, and Conviction of, Treason, Bribery, or other high Crimes and Misdemeanors. Further, Article II of the Constitution states that the President shall take Care that the Laws be faithfully executed, the Fourth Amendment of the Constitution states that The right of the people … against unreasonable searches and seizures, shall not be violated, and the Fifth Amendment of the Constitution states No person shall be … deprived of life, liberty, or property, without due process of law. In his conduct of the office of President of the United States—and in violation of his constitutional oath to faithfully to execute the office of President of the United States and, to the best of his ability, preserve, protect, and defend the Constitution of the United States, and in violation of his constitutional duty to take care that the laws be faithfully executed—Donald John Trump has abused the powers of the Presidency in a manner offensive to, and subversive of, the Constitution, in that: Using the power of his high office, Donald John Trump has engaged in this scheme or course of conduct through the following means: (1) By his orders and directions to subordinates, obstructed the administration of justice and embarked on a scheme to destroy and corrupt the legal system and the powers of the courts under Article III of the Constitution. Specifically, he has done the following: (A) Directed and permitted his subordinates and attorneys at the Department of Justice to violate their oaths to uphold the Constitution, laws of the United States, and the rules of professional ethics by adducing misleading and willfully false representations to the courts of the United States, and to otherwise abuse their official powers. Specifically, he has— (i) sought to dismiss, without prejudice and under false pretenses, the bribery and fraud charges against New York City Mayor Eric Adams, in an unethical quid pro quo exchange for the Defendant’s cooperation with the Administration’s political priorities, thus abusing the criminal laws to unconstitutionally commandeer a State officer and unit of government in violation of the sovereignty thereof; and (ii) terminated and purged career Department of Justice attorneys without reasonable cause and in violation of the law in retaliation for their legitimate investigatory and prosecutorial work under prior administrations, including in relation to the January 6, 2021, attack on the United States Capitol, and in retaliation for attorneys upholding their ethical and legal obligations including candor and honesty to the courts. (B) Directed and permitted the evasion and defiance of binding court orders. Specifically, he has— (i) removed persons from the United States to El Salvador despite an order from the United States District Court for the District of Columbia, for which said Court has found probable cause that the Government committed acts of criminal contempt; (ii) removed Kilmar Armando Abrego Garcia from the United States to El Salvador despite a binding Withholding of Removal order prohibiting the government from removing him to El Salvador; (iii) defied court orders, upheld by a unanimous ruling of the Supreme Court, to facilitate the release of Mr. Abrego Garcia, and related orders to provide information to the court and opposing counsel, while publicly flaunting their refusal; (iv) acted in contempt of court for violating a court-sanctioned settlement agreement; and (v) conducted enforced disappearances of persons without due process and without disclosing their fate and location to their families and legal counsel, in violation of the Constitution and the rulings of the Supreme Court, as well as the foundational principles of due process and the rule of law. (C) Directed and permitted the deliberate and systematic violation of laws duly enacted by Congress. Specifically, he has— (i) terminated Inspector Generals, the officers responsible for detecting and preventing waste by auditing and investigating their respective agencies’ operations and personnel, in violation of the process stipulated by the Inspector Generals Act of 1974, as subsequently amended; (ii) terminated a member of the Merit Systems Protection Board, a tribunal created to address widespread public concerns about the Federal civil service; and (iii) unlawfully transmitted sensitive personal information of private citizens and government employees in violation of, among other Federal laws, the Privacy Act and the Administrative Procedure Act. In all of this, Donald John Trump has willfully disregarded Federal laws and the Constitution, imperiled a coequal branch of Government, and threatened the integrity of the democratic system. He thereby betrayed his trust as President, abused the powers of the Presidency, acted in a manner grossly incompatible with self-governance and the rule of law, and has committed the High Crimes and Misdemeanors of obstruction of justice and effecting a wide-ranging scheme to destroy and corrupt the legal system and the powers of the courts under Article III of the Constitution. Wherefore, Donald John Trump, by such conduct, has demonstrated that he is unfit to govern a Nation by and for the people, has acted in a manner grossly incompatible with self-governance and the rule of law, and will remain a threat to the Constitution if allowed to remain in office.