They Won't Impeach
Shri Thanedar has been told to hold off on his articles of impeachment because "this is not the time" when forces are marshalling against him to vote him out of office next year. So much for that.
Material Quoted From: https://freespeechforpeople.org
Posted on May 8, 2025WASHINGTON, D.C. (May 8, 2025) – Impeach Trump Again, a nonpartisan campaign led by Free Speech For People, announced today that 500,000 Americans have joined the campaign for impeachment. This comes as Free Speech For People releases a formal impeachment resolution featuring sixteen fully documented articles of impeachment.
Material quoted from CBS
https://www.cbsnews.com/news/trump-impeachment-shri-thanedar/
Washington — Democratic Rep. Shri Thanedar of Michigan backed down from his attempt to force a vote on impeaching President Trump after it lacked support from his own party.
The House was expected to vote Wednesday evening to table Thanedar's motion to impeach Mr. Trump for alleged high crimes and misdemeanors, which would have effectively killed it.
Thanedar filed his seven articles of impeachment against Mr. Trump in April, but moved Tuesday to bring it up as "privileged," requiring the House to act on the motion within two legislative days. But Thanedar changed course by Wednesday afternoon after having conversations with his colleagues.
"Instead, I will add to my articles of impeachment and continue to rally the support of both Democrats and Republicans to defend the Constitution with me," he wrote, adding that he will "continue to pursue all avenues to put this President on notice and hold him accountable for his many impeachable crimes."Rep. Jamie Raskin, a Maryland Democrat, said he explained to Thanedar that "it's not enough to be right."
"You need consensus," Raskin said. "You need a strategy to move forward because impeachment as a constitutional matter is a mixed question of law and politics."
Thanedar's 29-page resolution accuses Mr. Trump of obstructing justice, overriding Congress' power to appropriate funds, abusing the power of the presidency, violating First Amendment rights and unlawfully creating the Department of Government Efficiency.
His effort was not expected to receive much support from Democrats. The three Democrats who were listed as initial co-sponsors of the resolution when it was introduced last month quickly pulled their names after learning it was not cleared by leadership. And, Rep. Pete Aguilar of California, the Democratic caucus chair, said the move to impeach Mr. Trump was impractical because Republicans control both chambers of Congress."This is not the right approach we should be taking," Aguilar told reporters earlier Wednesday, adding that Democratic leadership would be joining Republicans in voting to block the attempt.
Aguilar said Democrats are focused on Republican attempts to cut Medicaid through the reconciliation process as they seek to slash spending to pay for trillions in tax cuts.
"Everything else is a distraction," Aguilar said.
Thanedar acknowledged the hesitancy in his party to impeach Mr. Trump in a news conference Wednesday morning, but defended his action as something supported by the public and said that he would continue pushing the issue "until we have a victory."
"Many people in my party and elsewhere say, 'Is this the right time to do this?," he said. "People all over the country are saying this is the right time to do it!""Some Democrats have called me a lunatic, just like the president has called me lunatic," he said. "Nobody has said to me, 'Mr. Thanedar, the seven articles of impeachment that you presented to the U.S. Congress, they're piece of s***. They're not good. You missed the point.'"
The text below is the text of yet to be formerly filed Bill-119 hres353 articles of impeachment. The original is located at:
https://www.congress.gov/119/bills/hres353/BILLS-119hres353ih.pdf
IV
119TH CONGRESS
1ST SESSION H. RES. 353
Impeaching Donald John Trump, President of the United States,
for high crimes and misdemeanors.
IN THE HOUSE OF REPRESENTATIVES
APRIL 28, 2025
Mr. THANEDAR (for himself, Mr. MFUME, Mr. NADLER, and Ms. KELLY of
Illinois) submitted the following resolution; which was referred to the
Committee on the Judiciary
RESOLUTION
Impeaching Donald John Trump, President
of the United States, for high crimes and misdemeanors.
1
Resolved, That
Donald John Trump, President of the
2
United States, is impeached for high crimes and
mis3 demeanors, and that the following articles of impeachment 4 be exhibited
to the Senate:
5
Article of impeachment exhibited by the House of
6
Representatives of the United States of America
in the 7 name of itself and of the people of the United States of
8 America,
against Donald John Trump, President of the
9 United
States of America, in maintenance and support of
Frm 00001
its impeachment against him for high
crimes and misdemeanors.
ARTICLE I:
OBSTRUCTION
OF JUSTICE, VIOLATION OF
DUE PROCESS,
AND A
BREACH OF THE DUTY TO
5 FAITHFULLY
EXECUTE LAWS
6
7 The Constitution provides that the House
of Rep8 resentatives ‘‘shall have the sole Power of Impeachment’’ 9 and that
the President ‘‘shall be removed from Office on
10 Impeachment
for, and Conviction of, Treason, Bribery, or
11 other
high Crimes and Misdemeanors’’. Further, Article
12 II
of the Constitution states that the President ‘‘shall take
13 Care
that the Laws be faithfully executed’’, the Fourth
14 Amendment
of the Constitution states that ‘‘The right of
15 the
people . . . against unreasonable searches and sei16 zures, shall not be
violated’’, and the Fifth Amendment
17 of the Constitution states ‘‘No person
shall be . . . de18 prived of life, liberty, or property, without due process
of 19 law’’. In his conduct of the office of President of the
20 United States—and in violation of his
constitutional oath 21 to faithfully to execute the office of 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 and
in violation of his constitutional duty to take care that
25 the
laws be faithfully executed—Donald John Trump has
Frm 00002
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 5 through the following means:
6 (1) By his orders and directions to
subordi7 nates, obstructed the administration of justice and
8
embarked on a scheme to destroy and corrupt the
9
legal system and the powers of the courts under
Ar10 ticle III of the Constitution. Specifically, he has done 11 the following:
12
(A) Directed and permitted his subordi-
13
nates and attorneys at the Department of Jus-
14
tice to violate their oaths to uphold the Con15 stitution,
laws of the United States, and the
16 rules of professional ethics by
adducing mis17 leading and willfully false representations to the 18 courts of
the United States, and to otherwise
19
abuse their official powers. Specifically, he
20
has—
21
(i) sought to dismiss, without preju22 dice and
under false pretenses, the bribery
23
and fraud charges against New York City
24
Mayor Eric Adams, in an unethical quid
25
pro quo exchange for the Defendant’s co-
Frm 00003
operation with the Administration’s
political priorities, thus abusing the criminal laws to unconstitutionally
commandeer a
State officer and unit
of government in
5
violation of the sovereignty thereof; and
6
(ii) terminated and purged career De-
7
partment of Justice attorneys without rea8 sonable
cause and in violation of the law in 9 retaliation for their legitimate
investigatory
10
and prosecutorial work under prior admin-
11
istrations, including in relation to the Jan12 uary
6, 2021, attack on the United States
13
Capitol, and in retaliation for attorneys
14
upholding their ethical and legal obliga15 tions
including candor and honesty to the
16
courts.
17
(B) Directed and permitted the evasion
18
and defiance of binding court orders. Specifi-
19
cally, he has—
20
(i) removed persons from the United
21
States to El Salvador despite an order
22
from the United States District Court for
23
the District of Columbia, for which said
Court has found
probable cause that the
Frm 00004
Government committed acts of criminal
contempt;
(ii) removed Kilmar
Armando Abrego
Garcia from the United
States to El Sal-
5 vador despite a binding Withholding of Re6
moval order prohibiting the government 7 from removing him to El Salvador;
8 (iii) defied court orders, upheld by a 9 unanimous
ruling of the Supreme Court, to
10
facilitate the release of Mr. Abrego Garcia,
11
and related orders to provide information
12
to the court and opposing counsel, while
13
publicly flaunting their refusal;
14
(iv) acted in contempt of court for vio-
15
lating a court-sanctioned settlement agree-
16
ment; and
17
(v) conducted enforced disappearances
18
of persons without due process and without 19 disclosing
their fate and location to their
20
families and legal counsel, in violation of
21
the Constitution and the rulings of the Su22 preme
Court, as well as the foundational
23
principles of due process and the rule of
24
law.
Frm 00005
(C) Directed and
permitted the deliberate and systematic violation of laws duly enacted by
Congress. Specifically, he has—
(i) terminated
Inspector Generals, the
5
officers responsible for detecting and pre-
6
venting waste by auditing and inves-
7
tigating their respective agencies’ oper8 ations
and personnel, in violation of the
9
process stipulated by the Inspector Gen-
10
erals Act of 1974, as subsequently amend-
11
ed;
12
(ii) terminated a member of the Merit
13
Systems Protection Board, a tribunal cre14 ated
to address widespread public concerns 15 about the Federal civil service; and
16
(iii) unlawfully transmitted sensitive
17
personal information of private citizens 18 and
government employees in violation of,
19 among other Federal laws, the Privacy
Act 20 and the Administrative Procedure Act.
21 In all of this, Donald John Trump has
willfully dis22 regarded Federal laws and the Constitution, imperiled a
23 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,
Frm 00006
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
5 the legal system and the powers of the
courts under Article 6 III of the Constitution.
7
Wherefore, Donald John Trump, by such conduct,
8
has demonstrated that he is unfit to govern a
Nation by
9
and for the people, has acted in a manner
grossly incom10 patible with self-governance and the rule of law, and will
11 remain a threat to the Constitution if
allowed to remain 12 in office.
13 ARTICLE II:
USURPATION
OF THE APPROPRIATIONS
14 POWER
15
16 The Constitution provides that the
House of Rep17 resentatives ‘‘shall have the sole Power of Impeachment’’ 18 and
that the President ‘‘shall be removed from Office on 19 Impeachment for, and
Conviction of, Treason, Bribery, or 20 other high Crimes and Misdemeanors’’.
Further, Section 21 9 of Article I of the Constitution states that ‘‘No money
22 shall be drawn from the Treasury, but
in Consequence of 23 Appropriations made by Law’’. In his conduct of the office
24 of
President of the United States—and in violation of his
25 constitutional
oath to faithfully to execute the office of
26 President
of the United States and, to the best of his abil-
Frm 00007
ity, 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
5 a manner offensive to, and subversive of,
the Constitution, 6 in that:
7
Using the powers of his high office, Donald John
8
Trump unlawfully usurped Congress and its power
to ap9 propriate funds, thereby nullifying the Appropriations
10 Clause
in the Constitution and violating the Impoundment
11 Control
Act of 1974. Since taking office, he has signed
12 numerous
Executive Orders directing agencies to withhold
13 funds
appropriated by Congress. The President does not
14 have
the power to override spending laws or impound ap-
15 propriated
funds, a principle affirmed by numerous Su16 preme Court rulings.
17 Donald John Trump has withheld funds
and termi18 nated en masse Federal employees and numerous Federal 19 agencies
and departments, including the following:
20
(1) Directed the dismantling of the Department
21
of Education. As enacted in the Department of
Edu22 cation Organization Act, signed into law by Presi-
23 dent
Jimmy Carter, the Department of Education
was established by Congress to create
reform in the education system throughout the country, distribute
Frm 00008
Federal aid to students and places of
learning, and prohibit discriminatory practices. The President does not have
the authority to dismantle the Department of Education, and his signing of
Executive Order
5
14242, which aims to ‘‘Improving Education Out-
6
comes by Empowering Parents, States, and Commu7 nities’’,
violates the law and the Constitution.
8 (2) Unlawfully
directed the elimination of the 9 United States Agency for International
Development 10 (USAID). As enacted in the Foreign Assistance Act
11
of 1961, signed into law by President John F.
Ken-
12
nedy, USAID plays a crucial role in delivering
for13 eign assistance worldwide, including disaster relief,
14
conflict relief, combating global diseases,
promoting
15
educational programs, and enhancing food
security
16
in developing countries. By dismantling USAID
and
17
freezing foreign assistance, he has severed the 18
United States from its humanitarian role as directed 19 by Congress, leaving
other countries and potentially
20 our adversaries to fill in the role the
United States 21 has abandoned.
22 (3) Created the so-called ‘‘Department
of Gov23 ernment Efficiency (DOGE)’’, which has imposed
24 payment holds and
rescinded funds after disbursement. Donald John Trump has utilized DOGE to
Frm 00009
unlawfully block or impound appropriated funds to dozens of
Federal agencies, including the National Institutes of Health, the Federal
Aviation Administration, and the Department of Veterans Affairs. By 5 impounding congressionally appropriated
funds,
6 Donald John Trump and DOGE have not only
vio7 lated the law, but have negatively impacted the
8
American people by cutting jobs, halting
critical
9
services, and rescinding grants for programs, in
defi10 ance of the express, constitutionally binding will of
11
Congress.
12
Using the powers of his high office, Donald John
13
Trump has unlawfully withheld congressionally
appro14 priated funds and attempted to dismantle congressionally
15 mandated
agencies. By withholding funds and crippling
16 agencies,
he has prevented the Federal Government from
17 performing
critical duties here and abroad. He has threat18 ened the well-being of United
States citizens through the 19 gross misconduct of his office, resulting in
dire and life-
20 threatening consequences on the world’s
most vulnerable 21 populations.
22
Wherefore, Donald John Trump, by such conduct,
23
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
Frm 00010
remain a threat to the
Constitution if allowed to remain
in office.
ARTICLE III: ABUSE OF TRADE POWERS AND
INTERNATIONAL AGGRESSION
5
6 The Constitution provides that the House
of Rep7 resentatives ‘‘shall have the sole Power of Impeachment’’
8
and that the President ‘‘shall be removed from
Office on
9
Impeachment for, and Conviction of, Treason,
Bribery, or 10 other high Crimes and Misdemeanors’’. Further, Section 11 8 of
Article I of the Constitution states, ‘‘Congress shall
12 have
Power To lay and collect Taxes, Duties, Imposts and
13 Excises,
. . . but all Duties, Imposts and Excises shall
14 be
uniform throughout the United States’’. In his conduct
15 of
the office of President of the United States—and in
16 violation
of his constitutional oath to faithfully to execute
17 the
office of President of the United States and, to the
18 best
of his ability, preserve, protect, and defend the Con19 stitution of the United
States, and in violation of his con20 stitutional duty to take care that the
laws be faithfully 21 executed—Donald John Trump has abused the powers of
22 the Presidency in a manner offensive
to, and subversive 23 of, the Constitution, in that:
24
Using the powers of his high office, Donald John
25
Trump abused trade powers by imposing
unjustifiable and
26
unreasonable tariffs on foreign nations, causing
a sharp
Frm 00011
decline in the United States economy and
the economies of countries around the world, and declaring the false existence
of a national security emergency to justify his actions. Donald John Trump’s
tariffs contradicted trade
5 agreements
established by his Administration and other
6 administrations,
including the duly ratified and binding
7 treaty
obligations of the United States, thereby breaking
8 international
laws and norms, leading to countries around 9 the world to enact damaging
tariffs on goods and services
10 originating
from the United States. His ‘‘Liberation Day’’
11 scheme,
which imposed 10 percent tariffs on all countries,
12 as
well as additional tariffs based on a formula for ‘‘reci-
13 procity’’
widely mocked as nonsensical, led to the most sig14 nificant drop in the
financial markets since the 2020 crash 15 triggered by the COVID–19 pandemic.
16 Additionally, Donald John Trump has
threatened for17 eign nations with invasion, the annexation of territory, 18 and
the occupation of sovereign territory through the use 19 of military action. By
doing this, he has implicated the
20 United States and himself in violation
of constitutionally 21 binding treaty obligations, to include the North
Atlantic 22 Treaty of 1949, the General Treaty for Renunciation of
23 War as an
Instrument of National Policy of 1928, the Charter of the United Nations of
1945, and the Inter-
Frm 00012
American Treaty of Reciprocal Assistance
of 1947. Donald John Trump threatened the following:
(1) Annexation of the
sovereign country of Canada. Donald John Trump has negatively impacted
5
the deep and historic relationship between the
6
United States and Canada by stating numerous
7
times that Canada should become the 51st State,
8
under the threat of both economic coercion and
mili9 tary force.
10
(2) Unlawful and aggressive military action
11
within Mexico, to include drone strikes and the
use
12
of special operations military personnel,
ostensibly
13
against drug cartels, in violation of the
sovereignty
14
and territorial integrity of that country and
without
15
any congressional authorization to use military
force. 16 (3) Annexation of Greenland, an autonomous
17 territory
in the Kingdom of Denmark. Donald John 18 Trump
has continued to use hostile language aimed
19
at taking control of Greenland, stating that the
20
United States will ‘‘go as far as we have to
go’’ to 21 obtain control of Greenland. He has refused to rule
22
out military action to gain control of the
territory,
23
in violation of international law and despite
Den24 mark’s longstanding alliance and friendly relations 25 with the United
States.
Frm 00013
(4) Annexation of the
Panama Canal, owned and controlled by Panama. During a joint session speech to
Congress, Donald John Trump stated that his Administration ‘‘will be reclaiming
the Panama 5 Canal’’. He has refused to rule out military or eco6 nomic action
against the sovereign country.
7
(5) Annexation of the Gaza Strip, involving the
8
forced resettlement of the Palestinian
population to 9 the surrounding countries. Donald John Trump has
10
stated that the United States ‘‘will take over
the
11
Gaza Strip’’ and ‘‘own it’’. His proposal of
taking
12
over the Gaza Strip and the expulsion of its
popu-
13
lation violates international law, including the
Con14 vention on the Prevention and Punishment of the
15
Crime of Genocide, would be unconstitutional
absent
16
the approval of the United States Congress, and
is
17
profoundly unserious in light of the grave
humani18 tarian situation and ongoing armed conflict in Gaza. 19 Using the
powers of his high office, Donald John
20 Trump has unlawfully conducted himself,
bringing shame 21 and embarrassment to the office of the Presidency and
22 the
people of the United States. He has betrayed the trust
23 of
the Nation to conduct meaningful diplomatic negotiations as its chief diplomat
and failed to maintain peaceful economic and defense relations with foreign
countries. He
Frm 00014
has threatened the
security of the United States through gross misconduct of his office, prompting
hostilities towards Americans here and abroad, as well as foreign nations
warning their citizens against visiting the United 5 States, further harming
the Nation’s economy.
6
Wherefore, Donald John Trump, by such conduct,
7
has demonstrated that he is unfit to govern a
Nation by
8
and for the people, has acted in a manner
grossly incom9 patible with self-governance and the rule of law, and will
10 remain a threat to the Constitution if
allowed to remain 11 in office.
12 ARTICLE IV: VIOLATION OF FIRST AMENDMENT RIGHTS
13
14 The Constitution provides that the
House of Rep15 resentatives ‘‘shall have the sole Power of Impeachment’’
16 and
that the President ‘‘shall be removed from Office on
17 Impeachment
for, and Conviction of, Treason, Bribery, or 18 other high Crimes and
Misdemeanors’’. Further, the First 19 Amendment of the Constitution states
‘‘Congress shall
20 make
no law respecting an establishment of religion, or
21 prohibiting
the free exercise thereof; or abridging the free22 dom of speech, or of the
press; or the right of the people 23 peaceably to assemble, and to petition the
Government for
24 a redress of grievances’’. In his
conduct of the office of 25 President of the United States—and in violation of
his
26 constitutional oath to faithfully to execute the office
of
Frm 00015
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
5 John
Trump has abused the powers of the Presidency in
6 a
manner offensive to, and subversive of, the Constitution, 7 in that:
8 By his orders and directions to
subordinates, retali9 ated against law firms and attorneys who have advised or
10 represented,
or been associated with those who advise or
11 represent,
litigants who displease him, in violation of the
12 Constitution’s
prohibition on retaliation against individ13 uals for engaging in First
Amendment-protected conduct,
14 including
the right to petition the government for redress
15 of
grievances. Specifically, he has, barred attorneys at cer16 tain law firms from
access to Federal buildings, arbitrarily
17 revoked
security clearances without a reasonable basis,
18 threatened
to cancel Federal contracts with any entity en19 gaging the targeted attorneys
and firms, and demanded
20 pro bono services from law firms in
exchange for the dis21 continuation of the punitive Executive orders.
22
Additionally, Donald John Trump has engaged in a
23
pattern of unconstitutional, unlawful, and
corrupt retaliation against critics and political opponents, a flagrant
violation of constitutional rights protected by the First
Frm 00016
Amendment. He has weaponized the
Department of Justice and other agencies to engage in spurious investigations
and harassment, with no basis in law, of public figures and his perceived
political enemies.
5
Since taking office, Donald John Trump has
directed
6
the Department of Justice to dismiss more than a
dozen
7
prosecutors who were involved in investigations
against
8
him after he left office in 2021. The Department
of Jus9 tice has subsequently launched investigations into officials
10 involved
in prior probes against Donald John Trump, in
11 some
cases against individuals specifically named and ac12 cused in flagrantly
improper Executive orders.
13
Furthermore, he has made direct and unambiguous
14
public statements threatening media outlets,
current and
15
former officeholders, and advocacy
organizations. He has
16
pursued meritless litigation, leveraged his
public office for
17
private gain, and perverted the course of
justice and the 18 integrity of the judicial system to extract tens of millions
19 of
dollars in putative settlements, effectively acting as a
20 conduit
for flagrant bribery and extortion. He has re21 stricted the access of the
Associated Press after they re-
22 fused
to use the name ‘‘Gulf of America’’ in their report-
23 ing
and has defied court orders to cease this unconstitutional action. He has also
threatened current and former members of Congress for the exercise of their
legislative
Frm 00017
and oversight functions,
an attack on the independence of Congress as a coequal branch of government as
established by the Constitution’s Article I Vesting Clause, and by the
Constitution’s Speech or Debate Clause, in addition 5 to the First Amendment.
6
For example, Donald John Trump has repeatedly
7
threatened members of the House Select Committee
on
8
the January 6th Attack on the United States
Capitol, 9 which investigated the attack on the Capitol that Donald
10 John
Trump instigated. Donald John Trump has sought
11 to
intimidate the members and staff of the United States
12 House
Select Committee on the January 6th Attack, stat-
13 ing
that they ‘‘should fully understand that they are sub14 ject to investigation
at the highest level’’ and expressing
15 a
desire to remove the pardons they received, stating ‘‘The
16 ‘Pardons’
that Sleepy Joe Biden gave to the Unselect
17 Committee
of Political Thugs, and many others, are here-
18 by
declared [void, vacant, and of no further force or ef19 fect]’’.
20
Donald John Trump has made it clear that he will
21
not rest until all of his perceived political
enemies are
22
eliminated. In a speech addressing his
Department of Jus-
23
tice subordinates, Donald John Trump further
laid out his fascist vision for the Department of Justice. He has targeted
watchdog organizations like the Citizens for Respon-
Frm 00018
sibility and Ethics in Washington, calling
them ‘‘scum’’ and independent media outlets like CNN and MSNBC, labelling them
as organizations that ‘‘literally write 97.6 percent bad about me, are
political arms of the Democrat
5
Party. And in my opinion, they are really
corrupt and they
6
are illegal. What they do is illegal.’’. He has
stated that
7
newspapers critical of him are ‘‘really no
different than
8
a highly paid political operative. And it has to
stop. It 9 has to be illegal. It’s influencing judges . . . it just cannot 10 be
legal.’’.
11
By these and many other actions, he has sought
to
12
outlaw dissent, opposition, and criticism of
himself and his
13
Administration. This attack on the
constitutional rights
14
to freedom of speech, and of association, and of
the right
15
to petition the government for redress of
grievances, is
16
wholly incompatible with the rights and
liberties of the
17
People of the United States as a self-governing
people 18 under the rule of law.
19
In purpose and effect, he has attempted to
suppress
20
dissent and opposition, casting a chilling
effect over the
21
public discourse, and striking at the core
freedoms essen22 tial to a free society and democratic elections under the 23 Constitution.
Wherefore, Donald John
Trump, by such conduct, has demonstrated that he is unfit to govern a Nation by
Frm 00019
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.
5 ARTICLE
V: CREATION
OF UNLAWFUL OFFICE
6
7 The Constitution provides that the House
of Rep8 resentatives ‘‘shall have the sole Power of Impeachment’’ 9 and that
the President ‘‘shall be removed from Office on
10 Impeachment for, and Conviction of,
Treason, Bribery, or 11 other high Crimes and Misdemeanors’’. Further, Section 12
2 of Article II of the Constitution states that the President
13 ‘‘shall
appoint Ambassadors, other public Ministers and
14 Consuls,
Judges of the supreme Court, and all other Offi15 cers of the United States . .
. but the Congress may by
16 Law
vest the Appointment of such inferior Officers, as
17 they
think proper, in the President alone, in the Courts 18 of Law, or in the Heads
of Departments’’. In his conduct 19 of the office of President of the United
States—and in
20 violation of his constitutional oath to
faithfully to execute 21 the office of President of the United States and, to
the
22 best
of his ability, preserve, protect, and defend the Con-
23 stitution
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
Frm 00020
the Presidency in a manner offensive to,
and subversive of, the Constitution, in that:
Using the powers of his
high office, Donald John
Trump has, through
unlawful orders and directives, cre-
5 ated an unlawful office, the so-called
Department of Gov6 ernment Efficiency (‘‘DOGE’’), and assigned an extensive
7 range of unlawful powers, effectively
granting this fla8 grantly unconstitutional creation significant control over 9
the executive branch. Donald John Trump has appointed
10 Mr. Elon Musk as the de facto head of
this contrived enti11 ty, which was not created or funded by any law, without
12 a
formal title or office. These actions have been in direct
13 violation
of the Constitution’s requirement that principal
14 officers
of the United States must be created by law and
15 their
appointees confirmed by the Senate, and that inferior
16 offices
must be created by law with their appointment 17 vested as Congress may
determine.
18
Additionally, he has vested these powers in Mr.
Musk
19
without complying with the constitutional
requirement
20
that all officers of the United States be
commissioned by 21 the President and swear an oath of office to support the
22 Constitution.
Mr. Musk has been designated as a special
23 government
employee of the White House Office, in violation of statutory authorization and
restrictions on such designations. This false claim has also been used to com-
Frm 00021
mit
violations of the ethics, disclosure, and conflict-of-interest laws applicable
to government officers and regular employees.
Contrary to the
Government’s claims in court, Mr.
5 Musk
has exercised de facto control over DOGE and,
6 through
it, control over a wide range of Government de7 partments and agencies. This
unmistakable reality has
8 been repeatedly and openly stated by the
Trump Adminis9 tration, including by Donald John Trump’s own address
10 to
Congress on March 4, 2025. In this capacity, Mr. Musk
11 and
his subordinates have undertaken numerous violations 12 of the Constitution and
laws, including by—
13 (1) impoundment of funds appropriated
by 14 Congress;
15
(2) violations of privacy and security laws with
16
respect to sensitive information systems,
personally
17
identifiable information, and classified
material; and 18 (3) termination of government employees under
19
false pretenses and in violation of civil
service laws.
20
These actions have vastly exceeded the terms of
the
21
formal executive orders purporting to create
DOGE under 22 the direction of a ‘‘U.S. DOGE Service Administrator’’,
23 an office which
remained vacant for several weeks, with the Government’s own attorneys claiming
in court that the official head of DOGE was unknown to them. Since that
Frm 00022
time, a nominal
Administrator has been named, despite the repeated avowals from the President
and his Administration that Mr. Musk controls and directs DOGE, as confirmed by
ample public reporting and Mr. Musk’s own 5 statements.
6
Donald John Trump has abused the powers of his
7
high office and breached the public trust by
establishing
8
the so-called Department of Government
Efficiency and
9
unconstitutionally placing Mr. Musk in control
of this enti-
10
ty, knowingly provided false testimony to the
court regard-
11
ing the leadership of the said entity, and
directing the un12 lawful entity to implement his agenda, in violation of the
13 Constitution’s objective of
establishing Justice and funda14 mental rules for how the executive branch of
the United
15 States is to be structured and how
persons may be ap16 pointed to public office.
17
Wherefore, Donald John Trump, by such conduct,
18
has demonstrated that he is unfit to govern a
Nation by
19
and for the people, has acted in a manner
grossly incom20 patible with self-governance and the rule of law, and will
21 remain
a threat to the Constitution if allowed to remain
22 in
office.
23 ARTICLE
VI: BRIBERY
AND CORRUPTION
24
25
The Constitution provides that the House of Rep-
26
resentatives ‘‘shall have the sole Power of
Impeachment’’
Frm 00023
and that the President ‘‘shall be removed
from Office on Impeachment for, and Conviction of, Treason, Bribery, or other
high Crimes and Misdemeanors’’. Further, Section
9 of Article I of the
Constitution states that ‘‘no Person
5 holding
any Office of Profit or Trust under them, shall,
6 without
the Consent of the Congress, accept of any
7 present,
Emolument, Office, or Title, of any kind what8 ever, from any . . . foreign
State’’. In his conduct of the 9 office of President of the United States—and
in violation
10 of
his constitutional oath to faithfully to execute the office
11 of
President of the United States and, to the best of his
12 ability,
preserve, protect, and defend the Constitution of
13 the
United States, and in violation of his constitutional
14 duty
to take care that the laws be faithfully executed—
15 Donald
John Trump has abused the powers of the Presi-
16 dency
in a manner offensive to, and subversive of, the Con17 stitution, in that:
18 Donald John Trump has engaged in a
pattern of un19 lawful corruption for the personal profit of himself and
20 his
associates, soliciting and accepting bribes in exchange
21 for
official actions, policy influence, and favorable treat22 ment from the
Administration. In so doing, he has, beyond
23 a reasonable
doubt, profiteered from public office on a scale unprecedented in American
history.
Frm 00024
Donald John Trump has
engaged in fraudulent con artist schemes through ‘‘pump and dump’’ or ‘‘rug
pull’’ tactics for cryptocurrency tokens he has created, and at the same time,
enabled a direct conduit for bribes paid 5 to him in exchange for official
actions.
6
Donald John Trump has also leveraged the threat
of
7
hostile government action and the corresponding
offer of
8
preferential treatment in order to extract large
payments
9
in the form of settlements for meritless and
vexatious liti-
10
gation he pursues in his personal capacity,
thereby cor11 rupting both the executive branch and the judiciary. To
12 advance this end, Donald John Trump
solicited and re13 ceived $940,000,000 in pro bono services from prominent 14 law
firms to help causes he personally supports.
15
Donald John Trump has refused to divest himself
or
16
take any steps to prevent conflicts of interest
in his sub-
17
stantial personal business ventures, creating
another con18 duit for the payment of bribes.
19
Donald John Trump has permitted and encouraged
20
his subordinates to violate laws regarding
ethics, disclo21 sures, and self-dealing, and through these actions, he has
22 enabled and encouraged corruption and
graft by his rel23 atives, associates, and political allies.
Donald John Trump has,
in these ways and others, solicited payments from foreign governments for
corrupt
Frm 00025
purposes and in flagrant violation of the
Constitution’s prohibition on foreign emoluments.
Wherefore, Donald John
Trump, by such conduct, has demonstrated that he is unfit to govern a Nation by
5 and for the people, has acted in a manner grossly incom6 patible with
self-governance and the rule of law, and will
7 remain
a threat to the Constitution if allowed to remain
8 in
office.
9 ARTICLE
VII: TYRANNY
10
11 The Constitution provides that the
House of Rep12 resentatives ‘‘shall have the sole Power of Impeachment’’
13 and
that the President ‘‘shall be removed from Office on
14 Impeachment
for, and Conviction of, Treason, Bribery, or
15 other
high Crimes and Misdemeanors’’. Further, the sys16 tem of checks and balances,
as well as the separation of
17 powers, as defined in the Constitution,
work to ensure that 18 the Office of the President does not become tyrannical. 19
In his conduct of the office of President of the United
20 States—and in violation of his
constitutional oath to faith21 fully to execute the office of President of the
United States
22 and,
to the best of his ability, preserve, protect, and defend
23 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 pow-
Frm 00026
ers of the Presidency in a manner
offensive to, and subversive of, the Constitution, in that:
He has, by his actions
and statements, sought to establish himself as tyrant, dictator, and autocrat
over the
5 People
of the United States, usurping unto himself the
6 constitutional
powers of Congress, the courts, and the
7 States,
and powers illegitimate and beyond the scope of 8 lawful government altogether.
9
He has claimed for himself absolute and
arbitrary
10
power, the ability to suspend laws at whim, and
utterly
11
disregarded and betrayed his oath to faithfully
execute the
12
office of President of the United States and to
preserve,
13
protect, and defend the Constitution of the
United States.
14
He has denied and violated the right of the
People
15
of the United States to freedom of speech, and
of assem-
16
bly, and to petition the government for redress
of griev17 ances.
18
He has denied and violated the right of the
People
19
of the United States to due process of law and
equal pro20 tection under the laws, to fair and impartial independent 21 courts,
and to legal counsel.
22
He has sought to intimidate and coerce, by means
23
including the threat of unlawful prosecutions
and by encouraging violence and threats of violence, the Representatives and
Senators in Congress.
Frm 00027
He has denied and
violated the separation of powers and the Constitution’s system of checks and
balances, arrogating unto himself the legislative and judicial powers,
including the power of Congress to levy taxes, appropriate
5 public funds, direct the organization of
officers and agen6 cies of the executive branch, and to make laws.
7
He has sought to intimidate, coerce, and extort
the
8
officers of the several States, including those
elected by 9 the People thereof, and thereby sought to commandeer the
10 several
States, in violation of their sovereignty and the
11 system
of federalism established by the Constitution of the 12 United States.
13
He has sought to abrogate the citizenship clause
of
14
the 14th Amendment to the Constitution, by means
in-
15
cluding the issuance of an executive order that
directs ex16 ecutive departments and agencies to withhold citizenship
17 from certain classes of persons who are
born within the 18 United States.
19
He has repeatedly threatened and suggested that
he
20
intends to violate the Presidential term limits
established 21 by the 22d Amendment to the Constitution, and adopted 22 overtly
monarchical aspirations and affectations, including
23 by invoking and
endorsing theories that he is above the law or that his personal will
constitutes the law.
Frm 00028
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
5 trust
as President, abused the powers of the Presidency,
6 acted
in a manner grossly incompatible with self-govern7 ance and the rule of law,
and has committed High Crimes
8 and Misdemeanors in
attempting to establish himself as 9 a lawless tyrant to the manifest injury of
the people of 10 the United States.
11
Wherefore, Donald John Trump, by such conduct,
12
has demonstrated that he is unfit to govern a
Nation by
13
and for the people, has acted in a manner
grossly incom14 patible with self-governance and the rule of law, and will
15 remain
a threat to the Constitution if allowed to remain
16 in
office.
Æ
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