United States v. Nixon

United States v. Nixon, 418 U.S. 683 (1974), was a landmark United States Supreme Court case that resulted in a unanimous decision against President Richard Nixon, ordering him to deliver tape recordings and other subpoenaed materials to a federal district court. Issued on July 24, 1974, the decision was important to the late stages of the Watergate scandal, when there was an ongoing impeachment process against Richard Nixon. United States v. Nixon is considered a crucial precedent limiting the power of any U.S. president to claim executive privilege.

Chief Justice Warren E. Burger wrote the opinion for a unanimous court, joined by Justices William O. Douglas, William J. Brennan, Potter Stewart, Byron White, Thurgood Marshall, Harry Blackmun and Lewis F. Powell. Burger, Blackmun, and Powell were appointed to the Court by Nixon during his first term. Associate Justice William Rehnquist recused himself as he had previously served in the Nixon administration as an Assistant Attorney General.[1][2]

United States v. Nixon
Seal of the United States Supreme Court
Argued July 8, 1974
Decided July 24, 1974
Full case nameUnited States v. Richard Milhous Nixon, President of the United States, et al.
Citations418 U.S. 683 (more)
94 S. Ct. 3090; 41 L. Ed. 2d 1039; 1974 U.S. LEXIS 93
ArgumentOral argument
Case history
PriorUnited States v. Mitchell, 377 F. Supp. 1326 (D.D.C. 1974); cert. before judgment to the United States Court of Appeals for the District of Columbia Cir.
The Supreme Court does have the final voice in determining constitutional questions; no person, not even the president of the United States, is completely above the law; and the president cannot use executive privilege as an excuse to withhold evidence that is "demonstrably relevant in a criminal trial."
Court membership
Chief Justice
Warren E. Burger
Associate Justices
William O. Douglas · William J. Brennan Jr.
Potter Stewart · Byron White
Thurgood Marshall · Harry Blackmun
Lewis F. Powell Jr. · William Rehnquist
Case opinion
MajorityBurger, joined by Douglas, Brennan, Stewart, White, Marshall, Blackmun, Powell
Rehnquist took no part in the consideration or decision of the case.


The case arose out of the Watergate scandal, which began during the 1972 Presidential campaign between Democratic Senator George McGovern of South Dakota and President Nixon. On June 17, 1972, about five months before the general election, five burglars broke into Democratic headquarters located in the Watergate building complex in Washington, D.C.

In May 1973, Nixon's Attorney General, Elliot Richardson, appointed Archibald Cox to the position of special prosecutor, charged with investigating the break-in.[3] In October 1973, Nixon arranged to have Cox fired in the Saturday Night Massacre. Nonetheless, public outrage forced Nixon to appoint a new special prosecutor, Leon Jaworski, who was charged with conducting the Watergate investigation for the government.

In April 1974, Jaworski obtained a subpoena ordering Nixon to release certain tapes and papers related to specific meetings between the President and those indicted by the grand jury. Those tapes and the conversations they revealed were believed to contain damaging evidence involving the indicted men and perhaps the President himself.[4]

Hoping that Jaworski and the public would be satisfied, Nixon turned over edited transcripts of 43 conversations, including portions of 20 conversations demanded by the subpoena. James D. St. Clair, Nixon's attorney, then requested Judge John Sirica of the U.S. District Court for the District of Columbia to quash the subpoena. While arguing before Sirica, St. Clair stated that:

The President wants me to argue that he is as powerful a monarch as Louis XIV, only four years at a time, and is not subject to the processes of any court in the land except the court of impeachment.[5]

Sirica denied Nixon's motion and ordered the President to turn the tapes over by May 31.[6] Both Nixon and Jaworski appealed directly to the Supreme Court, which heard arguments on July 8. Nixon's attorney argued the matter should not be subject to "judicial resolution" since the matter was a dispute within the executive branch and the branch should resolve the dispute itself. Also, he claimed Special Prosecutor Jaworski had not proven the requested materials were absolutely necessary for the trial of the seven men. Besides, he claimed Nixon had an absolute executive privilege to protect communications between "high Government officials and those who advise and assist them in carrying out their duties."


Less than three weeks after oral arguments, the Court issued its decision.

Within the court, there was never much doubt about the general outcome, July 9, the day following oral arguments, all eight justices (Justice William H. Rehnquist recused himself due to his close association with several Watergate conspirators, including Attorneys General John Mitchell and Richard Kleindienst, prior to his appointment to the Court) indicated to each other that they would rule against the president.[7] The justices struggled to settle on an opinion that all eight could agree to, however, with the major issue being how much of a constitutional standard could be established for what executive privilege did mean.

Burger's first draft was deemed problematic and insufficient by the rest of the court, leading the other Justices to criticize and re-write major parts of the draft. The final draft would eventually heavily incorporate Justice Blackmun's re-writing of Facts of the Case, Justice Douglas' appealability section, Justice Brennan's thoughts on standing, Justice White's standards on admissibility and relevance, and Justices Powell and Stewart's interpretation of the executive privilege.[8]

The stakes were so high, in that the tapes most likely contained evidence of criminal wrongdoing by the President and his men, that they wanted no dissent.[9] Despite the Chief Justice's hostility to allowing the other Justices to participate in the drafting of the opinion, the final version was agreed to on July 23, the day before the decision was announced, and would contain the work of all the Justices.[10] Chief Justice Burger delivered the decision from the bench and the very fact that he was doing so meant that knowledgeable onlookers realized the decision must be unanimous.

The Court's opinion found that the courts could indeed intervene on the matter and that Special Counsel Jaworski had proven a "sufficient likelihood that each of the tapes contains conversations relevant to the offenses charged in the indictment". While the Court acknowledged that the principle of executive privilege did exist, the Court would also directly reject President Nixon's claim to an "absolute, unqualified Presidential privilege of immunity from judicial process under all circumstances."

The Court held that a claim of Presidential privilege as to materials subpoenaed for use in a criminal trial cannot override the needs of the judicial process if that claim is based, not on the ground that military or diplomatic secrets are implicated, but merely on the ground of a generalized interest in confidentiality. Nixon was then ordered to deliver the subpoenaed materials to the District Court.

Nixon resigned sixteen days later, on August 9, 1974.


  1. ^ The United States v. Nixon – Significance, Nixon Fights The Subpoena, Nixon Order To Release, Presidential Succession, Further Readings Law Library
  2. ^ Kutler, Stanley L. (1992). The Wars of Watergate. W. W. Norton & Company. p. 508. ISBN 0-393-30827-8. Retrieved May 4, 2009. Rehnquist recused himself in the case, citing his past association with the Nixon Administration.
  3. ^ "WATERGATE RETROSPECTIVE: THE DECLINE AND FALL". 19 August 1974 – via www.time.com.
  4. ^ "Can the President Be Indicted? A Long-Hidden Legal Memo Says Yes". Arthur Gregg Sulzberger. July 22, 2017.
  5. ^ Trachtman, Michael G. (2007). The Supremes' Greatest Hits: The 34 Supreme Court Cases That Most Directly Affect Your Life. Sterling. p. 131. ISBN 978-1-4027-4107-4. Retrieved 2011-05-12.
  6. ^ United States v. Mitchell, 377 F. Supp. 1326 (D.D.C. 1974).
  7. ^ Bob Woodward and Scott Armstrong, The Brethren, p. 368.
  8. ^ Woodward, p. 377
  9. ^ Woodward, p. 412
  10. ^ Woodward, p. 413

External links

Certiorari before judgment

A petition for certiorari before judgment, in the Supreme Court of the United States, is a petition for a writ of certiorari in which the Supreme Court is asked to immediately review the decision of a United States District Court, without an appeal having been decided by a United States Court of Appeals, for the purpose of expediting the proceedings and obtaining a final decision.

Certiorari before judgment is rarely granted. Supreme Court Rule 11 provides that this procedure will be followed "only upon a showing that the case is of such imperative public importance as to justify deviation from normal appellate practice and to require immediate determination in this Court." A writ of certiorari before judgment may be granted only in federal cases, and is not necessary in those cases where a statute authorizes a direct appeal from a District Court to the Supreme Court.

Well-known cases in which the Supreme Court has granted certiorari before judgment and heard the case on an expedited basis have included Ex parte Quirin (1942), United States v. United Mine Workers (1947), Youngstown Sheet & Tube Co. v. Sawyer (1952), United States v. Nixon (1974), Dames & Moore v. Regan (1981), Northern Pipeline Co. v. Marathon Pipe Line Co. (1982), United States v. Booker (2005) and Department of Commerce v. New York (2019).In United States v. Windsor (2013), both sides filed petitions for certiorari before judgment, but it was only granted after judgment by the Second Circuit.

Committee for the Re-Election of the President

The Committee for the Re-Election of the President (also known as the Committee to Re-elect the President), abbreviated as CRP was a fundraising organization of United States President Richard Nixon in his 1972 re-election campaign.

Executive privilege

Executive privilege is the power of the President of the United States and other members of the executive branch of the United States Government to resist certain subpoenas and other interventions by the legislative and judicial branches of government in pursuit of information or personnel relating to confidential communications that would impair governmental functions. The power of Congress or the federal courts to obtain such information is not mentioned explicitly in the United States Constitution, nor is there any explicit mention in the Constitution of an executive privilege to resist such requests from Congress or courts. The Supreme Court of the United States has ruled this privilege may qualify as an element of the separation of powers doctrine, derived from the supremacy of the executive branch in its own area of Constitutional activity.The Supreme Court confirmed the legitimacy of this doctrine in United States v. Nixon in the context of a subpoena emanating from the judiciary, instead of emanating from Congress. The Court held that there is a qualified privilege, which once invoked, creates a presumption of privilege, and the party seeking the documents must then make a "sufficient showing" that the "Presidential material" is "essential to the justice of the case". Chief Justice Warren Burger further stated that executive privilege would most effectively apply when the oversight of the executive would impair that branch's national security concerns. Regarding requests from Congress (instead of from the courts) for executive branch information, as of a 2014 study by the Congressional Research Service, only two federal court cases had addressed the merits of executive privilege in such a context, and neither of those cases reached the Supreme Court.In addition to which branch of government is requesting the information, another characteristic of executive privilege is whether it involves a "presidential communications privilege" or instead a "deliberative process privilege" or some other type of privilege. The deliberative process privilege is often considered to be rooted in common law, whereas the presidential communications privilege is often considered to be rooted in separation of powers, thus making the deliberative process privilege less difficult to overcome. Generally speaking, presidents, congresses and courts have historically tended to sidestep open confrontations through compromise and mutual deference in view of previous practice and precedents regarding the exercise of executive privilege.

Jennie Eisenhower

Jennie Elizabeth Eisenhower (born August 15, 1978) is an American actress. She has performed in a number of theater productions and had minor roles in some feature films. She is the great-grandchild and grandchild of Presidents Dwight D. Eisenhower and Richard Nixon, respectively.

Lewis F. Powell Jr.

Lewis Franklin Powell Jr. (September 19, 1907 – August 25, 1998) was an American lawyer and jurist who served as an Associate Justice of the Supreme Court of the United States, serving from 1971 to 1987. Powell compiled a conservative record on the Court and cultivated a reputation as a swing vote with a penchant for compromise.

Born in Suffolk, Virginia, he graduated from both Washington and Lee Law School and Harvard Law School and served in the United States Army Air Forces during World War II. He worked for a large law firm in Richmond, Virginia, focusing on corporate law and representing clients such as the Tobacco Institute. In 1971, President Richard Nixon appointed Powell to succeed Associate Justice Hugo Black. He retired from the Court during the administration of President Ronald Reagan, and was eventually succeeded by Anthony Kennedy.

His tenure largely overlapped with that of Chief Justice Warren Burger, and Powell was often a key swing vote on the Burger Court. His majority opinions include First National Bank of Boston v. Bellotti and McCleskey v. Kemp, and he wrote an influential opinion in Regents of the University of California v. Bakke. He notably joined the majority in cases such as United States v. Nixon, Roe v. Wade, Plyler v. Doe, and Bowers v. Hardwick.

List of United States Supreme Court cases, volume 235

This is a list of all the United States Supreme Court cases from volume 235 of the United States Reports:

North Carolina v. Tennessee, 235 U.S. 1 (1914)

Lane v. Watts, 235 U.S. 17 (1914)

Pullman Co. v. Knott, 235 U.S. 23 (1914)

United States v. Portale, 235 U.S. 27 (1914)

Overton v. Oklahoma, 235 U.S. 31 (1914)

DeJonge & Co. v. Breuker & Kessler Co., 235 U.S. 33 (1914)

Missouri, K. & T. R. Co. v. United States, 235 U.S. 37 (1914)

Taylor v. Parker, 235 U.S. 42 (1914)

Willoughby v. Chicago, 235 U.S. 45 (1914)

Cleveland & Pittsburgh R. Co. v. Cleveland, 235 U.S. 50 (1914)

United States v. Mayer, 235 U.S. 55 (1914)

United States v. Bartlett, 235 U.S. 72 (1914)

Monagas v. Albertucci, 235 U.S. 81 (1914)

L. E. Waterman Co. v. Modern Pen Co., 235 U.S. 88 (1914)

Sage v. Hampe, 235 U.S. 99 (1914)

Magruder v. Drury, 235 U.S. 106 (1914)

Missouri Pacific R. Co. v. Omaha, 235 U.S. 121 (1914)

United States v. Reynolds, 235 U.S. 133 (1914)

McCabe v. Atchison, T. & S. F. R. Co., 235 U.S. 151 (1914)

Louisiana R. & Nav. Co. v. Behrman, 235 U.S. 164 (1914)

New York Elec. Lines Co. v. Empire City Subway Co., 235 U.S. 179 (1914)

Sioux Remedy Co. v. Cope, 235 U.S. 197 (1914)

Skelton v. Dill, 235 U.S. 206 (1914)

Minidoka & Southwestern R. Co. v. United States, 235 U.S. 211 (1914)

Henry v. Henkel, 235 U.S. 219 (1914)

United States v. Nixon, 235 U.S. 231 (1914)

United States v. Salen, 235 U.S. 237 (1914)

Porto Rico v. Emmanuel, 235 U.S. 251 (1914)

Western Life Indemnity Co. of Ill. v. Rupp, 235 U.S. 261 (1914)

United States v. Wigger, 235 U.S. 276 (1914)

United States v. Lewis, 235 U.S. 282 (1914)

Hopkins v. Hebard, 235 U.S. 287 (1914)

Choctaw, O. & G. R. Co. v. Harrison, 235 U.S. 292 (1914)

Fallows v. Continental & Commercial Trust & Sav. Bank, 235 U.S. 300 (1914)

Garrett v. Louisville & Nashville R. Co., 235 U.S. 308 (1914)

United States v. Louisville & Nashville R. Co., 235 U.S. 314 (1914)

United States ex rel. Alexander Bryant Co. v. New York Steam Fitting Co., 235 U.S. 327 (1914)

John Ii Estate, Ltd. v. Brown, 235 U.S. 342 (1914)

St. Louis Southwestern R. Co. v. Arkansas, 235 U.S. 350 (1914)

Berwind-White Coal Mining Co. v. Chicago & Erie R. Co., 235 U.S. 371 (1914)

Yazoo & Mississippi Valley R. Co. v. Wright, 235 U.S. 376 (1914)

Easterling Lumber Co. v. Pierce, 235 U.S. 380 (1914)

Lovell-McConnell Mfg. Co. v. Automobile Supply Mfg. Co., 235 U.S. 383 (1914)

McGovern v. Philadelphia & Reading R. Co., 235 U.S. 389 (1914)

Detroit & Mackinac R. Co. v. Michigan Railroad Comm'n, 235 U.S. 402 (1914)

Scotten v. Littlefield, 235 U.S. 407 (1914)

Shapiro v. United States, 235 U.S. 412 (1914)

Adkins v. Arnold, 235 U.S. 417 (1914)

Washington v. Miller, 235 U.S. 422 (1914)

Texas & Pacific R. Co. v. Rosborough, 235 U.S. 429 (1914)

Drew v. Thaw, 235 U.S. 432 (1914)

Sizemore v. Brady, 235 U.S. 441 (1914)

Maryland Steel Co. of Baltimore Cty. v. United States, 235 U.S. 451 (1915)

Lankford v. Platte Iron Works Co., 235 U.S. 461 (1915)

American Water Softener Co. v. Lankford, 235 U.S. 496 (1915)

Farish v. State Banking Bd. of Okla., 235 U.S. 498 (1915)

United States v. Erie R. Co., 235 U.S. 513 (1915)

Lawlor v. Loewe, 235 U.S. 522 (1915)

South Covington & Cincinnati Street R. Co. v. City of Covington, 235 U.S. 537 (1915)

New York ex rel. Cornell S. S. Co. v. Sohmer, 235 U.S. 549 (1915)

Gilbert v. David, 235 U.S. 561 (1915)

Jeffrey Mfg. Co. v. Blagg, 235 U.S. 571 (1915)

Mercelis v. Wilson, 235 U.S. 579 (1915)

Hull v. Dicks, 235 U.S. 584 (1915)

Brown v. Fletcher, 235 U.S. 589 (1915)

Louisville & Nashville R. Co. v. Finn, 235 U.S. 601 (1915)

Hendrick v. Maryland, 235 U.S. 610 (1915)

Norfolk & Western R. Co. v. Holbrook, 235 U.S. 625 (1915)

Wathen v. Jackson Oil & Refining Co., 235 U.S. 635 (1915)

Dowagiac Mfg. Co. v. Minnesota Moline Plow Co., 235 U.S. 641 (1915)

Wadley Southern R. Co. v. Georgia, 235 U.S. 651 (1915)

Arizona & New Mexico R. Co. v. Clark, 235 U.S. 669 (1915)

List of United States Supreme Court cases, volume 418

This is a list of all the United States Supreme Court cases from volume 418 of the United States Reports:

Commissioner v. Idaho Power Co., 418 U.S. 1 (1974)

Richardson v. Ramirez, 418 U.S. 24 (1974)

Hamling v. United States, 418 U.S. 87 (1974)

Jenkins v. Georgia, 418 U.S. 153 (1974)

United States v. Richardson, 418 U.S. 166 (1974)

Schlesinger v. Reservists Comm. to Stop the War, 418 U.S. 208 (1974)

Miami Herald Publishing Co. v. Tornillo, 418 U.S. 241 (1974)

Letter Carriers v. Austin, 418 U.S. 264 (1974)

Lehman v. Shaker Heights, 418 U.S. 298 (1974)

Gertz v. Robert Welch, Inc., 418 U.S. 323 (1974)

Spence v. Washington, 418 U.S. 405 (1974) (per curiam)

Dorszynski v. United States, 418 U.S. 424 (1974)

Wingo v. Wedding, 418 U.S. 461 (1974)

Taylor v. Hayes, 418 U.S. 488 (1974)

Codispoti v. Pennsylvania, 418 U.S. 506 (1974)

Wolff v. McDonnell, 418 U.S. 539 (1974)

United States v. Marine Bancorporation, Inc., 418 U.S. 602 (1974)

United States v. Connecticut Nat. Bank, 418 U.S. 656 (1974)

Secretary of Navy v. Avrech, 418 U.S. 676 (1974) (per curiam)

United States v. Nixon, 418 U.S. 683 (1974)

Milliken v. Bradley, 418 U.S. 717 (1974)

In re Grand Jury Proceedings, 418 U.S. 1301 (1974)

Master list of Nixon's political opponents

A master list of Nixon political opponents was compiled to supplement the original Nixon's Enemies List of 20 key people considered opponents of President Richard Nixon. The master list was compiled by Charles Colson's office and sent in memorandum form to John Dean. Dean later provided to the Senate Watergate Committee this updated "master list" of political opponents. The original list split out "Black Congressmen", listing "all of the Black congressmen [and congresswomen]".

Nixon White House tapes

The Nixon White House tapes are audio recordings of conversations between U.S. President Richard Nixon and Nixon administration officials, Nixon family members, and White House staff, produced between 1971 and 1973.In February 1971, a sound-activated taping system was installed in the Oval Office, including in Nixon's Oval Office desk, using Sony TC-800B open-reel tape recorders to capture audio transmitted by telephone taps and concealed microphones. The system was expanded to include other rooms within the White House and Camp David. The system was turned off on July 18, 1973, two days after it became public knowledge as a result of the Senate Watergate Committee hearings. Nixon was not the first president to record his White House conversations; the practice was initiated by President Franklin D. Roosevelt in 1940.

The tapes' existence came to light during the Watergate scandal of 1973 and 1974, when the system was mentioned during the televised testimony of White House aide Alexander Butterfield before the Senate Watergate Committee. Nixon's refusal of a congressional subpoena to release the tapes constituted an article of impeachment against Nixon, and led to his subsequent resignation on August 9, 1974.On August 19, 2013, the Nixon Library and the National Archives and Records Administration released the final 340 hours of the tapes that cover the period from April 9 through July 12, 1973.

Powers of the President of the United States

The powers of the President of the United States include those powers explicitly granted by Article II of the United States Constitution to the President of the United States, powers granted by Acts of Congress, implied powers, and also a great deal of soft power that is attached to the presidency.

The Constitution explicitly assigns the president the power to sign or veto legislation, command the armed forces, ask for the written opinion of their Cabinet, convene or adjourn Congress, grant reprieves and pardons, and receive ambassadors. The President oversees federal law execution by directing and removing executive officers. The president may make treaties, which need to be ratified by two-thirds of the Senate, and is accorded those foreign-affairs functions not otherwise granted to Congress or shared with the Senate. Thus, the President can control the formation and communication of foreign policy and can direct the nation's diplomatic corps. The president may also appoint Article III judges and some officers with the advice and consent of the U.S. Senate. In the condition of a Senate recess, the president may make a temporary appointment.

Rose Mary Woods

Rose Mary Woods (December 26, 1917 – January 22, 2005) was Richard Nixon's secretary from his days in Congress in 1951, through the end of his political career. Before H. R. Haldeman and John Ehrlichman became the operators of Nixon's presidential campaign, Woods was Nixon's gatekeeper.

Saturday Night Massacre

The Saturday Night Massacre is the name popularly applied to the series of events that took place in the United States on the evening of Saturday, October 20, 1973, during the Watergate scandal. U.S. President Richard Nixon ordered Attorney General Elliot Richardson to fire independent special prosecutor Archibald Cox; Richardson refused and resigned effective immediately. Nixon then ordered Deputy Attorney General William Ruckelshaus to fire Cox; Ruckelshaus refused, and also resigned. Nixon then ordered the third-most-senior official at the Justice Department, Solicitor General Robert Bork, to fire Cox. Bork considered resigning, but did as Nixon asked. The political and public reaction to Nixon's actions were negative and highly damaging to the president. A new special counsel was appointed eleven days later on November 1, 1973, and on November 14, 1973, a court ruled that the dismissal had been illegal.

The Brethren (book)

The Brethren: Inside the Supreme Court is a 1979 book by Bob Woodward and Scott Armstrong. It gives a "behind-the-scenes" account of the United States Supreme Court during Warren Burger's early years as Chief Justice of the United States. The book covers the years from the 1969 term through the 1975 term. Using Woodward's trademark writing technique involving "off-the-record" sources, the book provides an account of the deliberations leading to some of the court's more controversial decisions from the 1970s. Among the cases with substantial treatment in the book was the decision in United States v. Nixon (1974), where the Supreme Court unanimously ruled that President Richard Nixon was legally obligated to turn over the Watergate tapes. In 1985, upon the death of Associate Justice Potter Stewart, Woodward disclosed that Stewart had been the primary source for The Brethren.The book's sources are highly critical of Burger as Chief Justice, especially in comparison to his predecessor, Earl Warren. Burger is described by other Justices as pompous, devious, and intellectually inferior. The book is also critical at various points of William O. Douglas, who is portrayed as having gone from one of America's greatest jurists to a "nasty, petulant, prodigal child" who was overly political, and is also occasionally critical of another liberal stalwart, Thurgood Marshall, for his intellectual laziness and apathy.

The book does frequently lend out praise to other Justices though. Stewart, who was one of the primary sources for the book, is portrayed in a positive light, as is William J. Brennan, the acknowledged leader of the liberal bloc of justices, both for his intelligence as well as his amiable, friendly personality. The book also issued some particular praise for Justices Harlan and Powell.

Timeline of the Watergate scandal

Timeline of the Watergate Scandal —Regarding the burglary and illegal wiretapping of the Washington, D.C. headquarters of the Democratic National Committee in the Watergate complex by members of President of the United States Richard Nixon's re-election committee and subsequent abuse of powers by the president and administration officials to halt or hinder the investigation into the same.

United States v. R. Enterprises, Inc.

United States v. R. Enterprises, Inc., 498 U.S. 292 (1991), was a United States Supreme Court case in which the court held that the three prong test for the issuance of a subpoena in United States v. Nixon does not apply to subpoenas issued by a grand jury. The Court concluded by stating that when a grand jury subpoena is challenged on relevancy grounds, the motion to quash must be denied “unless the district court determines that there is no reasonable possibility that the materials sought will produce information relevant to the grand jury's investigation.”

Virgilio Gonzalez

Virgilio (Villo) R. Gonzalez (born May 18, 1926) is a Cuba-born political activist, locksmith, and one of the five men arrested at the Democratic National Committee headquarters at the Watergate complex on June 17, 1972. The break-in led to the Watergate scandal and the eventual resignation of United States President Richard Nixon two years later.

Warren E. Burger

Warren Earl Burger (September 17, 1907 – June 25, 1995) was the 15th Chief Justice of the United States, serving from 1969 to 1986. Born in Saint Paul, Minnesota, Burger graduated from the St. Paul College of Law in 1931. He helped secure the Minnesota delegation's support for Dwight D. Eisenhower at the 1952 Republican National Convention. After Eisenhower won the 1952 presidential election, he appointed Burger to the position of Assistant Attorney General in charge of the Civil Division. In 1956, Eisenhower appointed Burger to the United States Court of Appeals for the District of Columbia Circuit. Burger served on this court until 1969 and became known as a critic of the Warren Court.

In 1969, President Richard Nixon nominated Burger to succeed Chief Justice Earl Warren, and Burger won Senate confirmation. He did not emerge as a strong intellectual force on the court, but sought to improve the administration of the federal judiciary. He also helped establish the National Center for State Courts and the Supreme Court Historical Society. Burger remained on the court until his retirement in 1986, when he became Chairman of the Commission on the Bicentennial of the United States Constitution. He was succeeded as Chief Justice by William H. Rehnquist, who had served as an Associate Justice since 1971.

In 1974, Burger wrote for a unanimous court in United States v. Nixon, which rejected Nixon's invocation of executive privilege in the wake of the Watergate scandal. The ruling played a major role in Nixon's resignation. Burger joined the majority in Roe v. Wade in holding that the right to privacy prohibited states from banning abortions. He later abandoned Roe v. Wade in Thornburgh v. American College of Obstetricians and Gynecologists. His majority opinion in INS v. Chadha struck down the one-house legislative veto.

Although Burger was perceived as a conservative, and the Burger Court delivered numerous conservative decisions, the Burger Court also delivered some liberal decisions regarding abortion, capital punishment, religious establishment, and school desegregation during his tenure.

Watergate scandal

The Watergate scandal was a major political scandal that occurred in the United States during 1972 to 1974, following a break-in by five men at the Democratic National Committee (DNC) headquarters at the Watergate office complex in Washington, D.C. on June 17, 1972, and President Richard Nixon's administration's subsequent attempt to cover up his involvement. After the five burglars were caught and the conspiracy was discovered—chiefly through the work of a few journalists, Congressional staffers and an election-finance watchdog official—Watergate was investigated by the United States Congress. Meanwhile, Nixon's administration resisted its probes, which led to a constitutional crisis.The term Watergate, by metonymy, has come to encompass an array of clandestine and often illegal activities undertaken by members of the Nixon administration. Those activities included such dirty tricks as bugging the offices of political opponents and people of whom Nixon or his officials were suspicious. Nixon and his close aides also ordered investigations of activist groups and political figures, using the Federal Bureau of Investigation (FBI), the Central Intelligence Agency (CIA), and the Internal Revenue Service (IRS) as political weapons.The scandal led to the discovery of multiple abuses of power by members of the Nixon administration, the commencement of an impeachment process against the president, and Nixon's resignation. The scandal also resulted in the indictment of 69 people, with trials or pleas resulting in 48 being found guilty, many of whom were top Nixon officials.The affair began with the arrest of five men for breaking into the DNC headquarters at the Watergate complex on Saturday, June 17, 1972. The FBI investigated and discovered a connection between cash found on the burglars and a slush fund used by the Committee for the Re-Election of the President (CRP), the official organization of Nixon's campaign. In July 1973, evidence mounted against the president's staff, including testimony provided by former staff members in an investigation conducted by the Senate Watergate Committee. The investigation revealed that Nixon had a tape-recording system in his offices and that he had recorded many conversations.After a series of court battles, the Supreme Court of the United States unanimously ruled that the president was obligated to release the tapes to government investigators (United States v. Nixon). The tapes revealed that Nixon had attempted to cover up activities that took place after the break-in, and to use federal officials to deflect the investigation.

Facing virtually certain impeachment in the House of Representatives and equally certain conviction by the Senate, Nixon resigned the presidency on August 9, 1974, preventing the House from impeaching him. On September 8, 1974, his successor, Gerald Ford, pardoned him.

The name "Watergate" and the suffix "-gate", used after an identifying term (e.g. Bridgegate), have since become synonymous with political and non-political scandals in the United States, and some other parts of the world.

White House Plumbers

The White House Plumbers, sometimes simply called the Plumbers, the "Room 16 Project," or more officially, the White House "Special Investigations Unit" was a covert White House Special Investigations Unit, established within a week after the publication of the "Pentagon Papers" in June 1971, during the presidency of Richard Nixon. Its task was to stop and/or respond to the leaking of classified information, such as the Pentagon Papers, to the news media. The work of the unit "tapered-off" after the bungled "Ellsberg break-in" but some of its former operatives branched into illegal activities while still employed at the White House together with managers of the Committee to Re-elect the President, including the Watergate break-in and the ensuing Watergate scandal. The group has been described as Nixon's "fixers".

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