Impeachment investigations of United States federal officials

Numerous federal officials in the United States have been threatened with impeachment and removal from office. Most have not got very far, but were quite controversial in their time. Below is a summary of those few which actually were introduced in Congress.

Contents

Presidents

Only two presidents, Andrew Johnson and Bill Clinton, have been impeached in the history of the United States. However, both were acquitted by the United States Senate and not actually removed from office; removal requires an impeachment vote from the House of Representatives and a conviction from the Senate.

John Tyler

There were a number of failed attempts to remove President John Tyler from office.

On January 10, 1843, a resolution introduced by Rep. John Minor Botts, of Virginia, charged "John Tyler, Vice President acting as President" with nine counts of impeachable offenses, including corruption, official misconduct, and other high crimes and misdemeanors.[1] The resolution was defeated, 83-127.

After Tyler vetoed a tariff bill in June 1842, the House of Representatives initiated the first impeachment proceedings against a president in American history. A committee headed by former president John Quincy Adams, who was now a congressman, condemned Tyler's use of the veto and stated that Tyler should be impeached.[2] (This was not only a matter of the Whigs supporting the bank and tariff legislation which Tyler vetoed. Until the presidency of the Whigs' archenemy Andrew Jackson, presidents vetoed bills rarely, and then generally on constitutional rather than policy grounds,[3] so Tyler's actions also went against the Whigs' concept of the presidency.) Adams then proposed a constitutional amendment to change the two-thirds requirement to override a veto to a simple majority, but neither house passed such a measure.

James Buchanan

During most of 1860, the "Covode Committee" held hearings on whether to impeach President James Buchanan. While it found no real cause, it did find that his administration was the most corrupt since the foundation of the Republic.

Andrew Johnson

There were several attempts to remove President Andrew Johnson from office. The first occurred on On January 7, 1867, when Rep. James M. Ashley of Ohio, introduced a resolution accusing him of "corruption.".[4] On November 21, 1867, the House Judiciary committee produced a bill of impeachment that consisted of a vast collection of complaints against him. After a furious debate, a formal vote was held in the House of Representatives on December 5, 1867, which failed 57-108.[5]

Another try the following year succeeded and at the Senate trial, Johnson was acquitted by one vote.

Ulysses S. Grant

Near the end of his term in 1877, among the tumult of the Hayes/Tildon election mess, several Democratic congressmen threatened to impeach President Ulysses S. Grant for various sundry scandals.

Herbert Hoover

During the lame duck session of Congress in 1932-33, Congressman Louis Thomas McFadden twice introduced impeachment resolutions against President Herbert Hoover.[6] The resolutions were tabled.by wide margins.[7]

Harry S. Truman

In April 1951, President Harry S. Truman fired General of the Army Douglas MacArthur. The Republicans in the Congress made numerous calls for Truman's head. There were hearings in the Senate, and a year later, Congressmen George H. Bender and Paul W. Shafer separately introduced , H.R. Res. 607 and 614, against President Truman. The resolution was referred to the Judiciary Committee,[8] which being run by Democrats, sat on them. However, the US Senate held extensive hearings on the matter.

Lyndon B. Johnson

IN the fall of 1968, Rep. Bella Abzug introduced a resolution to impeach President Lyndon B. Johnson, which was sent to the House Judiciary Committee and soon buried.

Richard M. Nixon

On May 9, 1972, Congressman Leo Ryan submitted a resolution, H. Res. 975, to impeach President Richard Nixon. The resolution was referred to the Judiciary Committee.[9] The next day, John Conyers introduced a similar resolution, H. Res. 976, and both referred to the Judiciary Committee. Id. at 16,663. On May 18, 1972, Mr. Conyers introduced his second resolution, H. Res. 989, calling for President Nixon's impeachment. The resolution was referred to the Judiciary Committee, where they died.

As the Watergate affair heated up in the summer of 1973, Rep Robert Drinan tried again, and introduced H.R. Res. 513, was introduced on July 31, The resolution was referred to the Judiciary Committee,[10] which at the time didn't really want to get involved with such a wrenching process. Then came the So-called Saturday Night Massacre, and "all hell broke loose."

On October 23, 1973, a landslide of resolutions calling for impeachment, impeachment investigations, and the appointment of a special prosecutor were introduced against President Nixon.[11] The introduction of these resolutions continued for several days, but the Judiciary committee refused to start a formal investigation, especially with the Vice Presidency vacant after the resignation of Spiro Agnew less than two weeks before.

With pressure growing and a new Vice President in place, the House passed a resolution, H. Res. 803, on February 6, 1974, giving the Judiciary Committee authority to actually investigate the charges against the President.[12]

The hearings lasted until the summer, when after much wrangling, the Judiciary Committee voted out three articles of impeachment to the floor of the full House, the first time anything like this had got that far in over a century.

With the release of new tapes after the administration lost the case of US v. Nixon, and with Impeachment and removal by the Senate all but certain, Nixon became the first president to resign on August 9, 1974.

Ronald Reagan

On March 6, 1987 Rep. Henry B. Gonzalez, Democrat of Texas, introduced articles of impeachment against President Ronald Reagan regarding the Iran Contra affair, leading to the joint hearings that dominated the summer. A special prosecuter was appointed.

George H. W. Bush

On January 16, 1991, Congressman Henry B. Gonzalez introduced H. Res. 34, to impeach President George H. W. Bush for starting the Gulf War. The resolution was referred to the Judiciary Committee, where it died.[13] Gonzalez tried again with H. Res. 86 on February 21. Both bills were referred to the Subcommittee on Economic and Commercial Law March 18, 1992, where the effort died.

Bill Clinton

On November 5, 1997, Rep. Robert Barr introduced a resolution, H.R. Res. 304, directing the House Judiciary Committee to inquire into impeachment proceedings[14]—months before the Monica Lewinsky scandal came to light. Foremost among the concerns Barr cited at the time was apparent obstruction of Justice Department investigations into Clinton campaign fundraising from foreign sources, chiefly the People's Republic of China.[15] The resolution was referred to the Rules Committee for further action,.[16] which deems that none was necessary. Just a couple of months later, the Lewinsky Affair broke, leading to a frenzy of scandal and Clinton's impeachment and acquittal.

George W. Bush

Vice Presidents

Schuyler Colfax

Vice President Schuyler Colfax's name surfaced during witness testimony in a House "investigation of Crédit Mobilier scandal. Under this cloud of suspicion, on February 20, 1873, Congressman Fernando Wood introduced a resolution to investigate the Vice President's conduct.[17] The House, however, refused to consider Mr. Wood's resolution, primarily because Colfax was leaving office in a little over two weeks. Then a second resolution was introduced by Congressman Tyner, calling for a general investigation into the witness testimony to see if anyone else warranted impeachment. This resolution was adopted and referred to the Judiciary Committee, which buried it.

Spiro Agnew

In the early spring of 1973, the U.S. attorney in Maryland, investigating illegal campaign contributions and kickbacks, discovered that Vice President Spiro Agnew had been taking kickbacks from local contractors as late as December 1972. The scandal became public in the summer of that year, and as the days progressed, it appeared that an indictment was imminent. So, on the theory that a sitting Vice President couldn't be indicted, at least while an impeachment proceeding was going on, Agnew asked the House to start one in a letter dated September 15, 1973.[18]

On September 26, 1973, the House took up debate on Vice President Agnew's request. Congressman Paul Findley offered a resolution, H. Res. 569, appointing a Select Committee to investigate the Vice President. The resolution was referred to the Rules Committee, which sat on it while Attorney General Elliot Richardson negotiated a plea bargain with the soon-to-be-disgraced Vice President.

Agnew resigned on October 10, 1973, by unanimous consent of the House, the Judiciary Committee was discharged from further investigation under House Resolution 572.

George H. W. Bush

Dick Cheney

Cabinet secretaries

Secretary of War William Belknap

He was impeached by a unanimous vote of the House of Representatives shortly after he had resigned for allegedly having received money in return for post tradership appointments.[19] Speaker of the House Michael C. Kerr wrote to the Senate that Belknap resigned "with intent to evade the proceedings of impeachment against him."[20] Belknap was tried by the Senate, which ruled by a vote of 37-29 that it had jurisdiction despite the resignation.[21] The vote on conviction fell short of the two-thirds required, with 35 to 37 votes for each article and 25 votes against each. Two of those voting for conviction, 22 of those voting for acquittal, and one who declined to vote said they felt that the Senate did not have jurisdiction due to Belknap's resignation.[22]

Attorney General Harry M. Daugherty

In 1922, there the House Judiciary committee held hearings on whether to impeach Attorney General Harry Daugherty. Despite evidence of wrongdoing, impeachment articles weren't reported to the full House.

However it was his alleged knowledge of a kickback scam involving bootleggers (operated by his chief aide Jess Smith) that led to his eventual resignation on March 28, 1924. As the subject of a U.S. Senate investigation begun the year before, spearheaded under the direction of Senator Burton K. Wheeler of Montana, Daugherty, was eventually found not guilty in the investigation.

Secretary of the Treasury Andrew Mellon

In January 1932,[23] Rep. Wright Patman and others introduced articles of Impeachment against Andrew Mellon, with hearings before the House Judiciary Committee at the end of that month.[24] After the hearings were over, but before the scheduled vote on whether to report the articles to the full House. Mellon accepted an appointment to the post of Ambassador to the Court of St. James, and resigned, thus rendering further action on the issue moot.

Secretary of the Treasury William Woodin, Eugene Meyer, Andrew Mellon and Federal Reserve Board

On On May 23, 1933[25] Rep. Louis Thomas McFadden introduced articles of Impeachment against Eugene Meyer, Secretary of the Treasury William Woodin,[26] two former Treasury Secretaries (Andrew Mellon and Ogden L. Mills); J. F. T. O'Connor (Comptroller of Currency); John W. Pole (former Comptroller of Currency); four members and three former members of the Federal Reserve Board; twelve Federal Reserve Agents; and one former Federal Reserve Agent. There was a hearing on the subject before the House Judiciary committee, but nothing became of it.

Francis Perkins -- Labor Secretary, James Houghteling -- Immigration and Naturalization Commissioner and Gerard Reilly -- Solicitor of the Department of Labor

On January 24, 1939, Rep. J. Parnell Thomas offered an impeachment resolution against the above federal officials.[27] The resolution was referred to the Judiciary Committee [28] where it died a quiet death.

Congressional conservatives were angered with Secretary Francis Perkins when she had refused to deport Harry Bridges, the head of the International Longshore and Warehouse Union. Bridges, an Australian longshoreman who came to America in 1920, was accused of being a Communist.

Griffin Bell -- Attorney General of the United States

On February 6, 1978, a resolution, H. Res. 1002, was introduced authorizing Judiciary Committee to investigate Attorney General Griffin Bell. The resolution was referred to the Rules Committee.[29] A week later, Rep Philip Crane, introduced H. Res. 1025. It was also referred to the Rules Committee.[30] and both never saw the light of day again.

Donald Rumsfeld -- Secretary of Defense of the United States

On June 20, 2004, angered by the War in Iraq, Rep. Charles Rangel and four co-sponsors introduced H.Res 629 which sought impeachment hearings by the Judiciary Committee against Secretary Donald Rumsfeld. It was referred to the HJC's subcommittee on the Constitution, where it died.

Alberto Gonzales -- Attorney General of the United States

On July 7, 2007, Rep. Jay Inslee and 31 co-sponsors introduced H. Res. 589 which sought impeachment hearings by the Judiciary Committee against Attorney General Alberto Gonzales.[31] It was referred to the Rules Committee instead. Gonzales resigned two months later.

The Federal Reserve Board

The three attempts to remove all or part of the Federal Reserve Board failed.

Lindbergh's attempt

On February 12, 1917, Rep Charles Lindbergh, Sr., father of "Lucky Lindy", offered articles of impeachment against five members of the Federal Reserve Board. The articles were referred to the Judiciary Committee for investigation.[32][33] On March 3, the Judiciary Committee submitted its report, H.R. Rep. 64-1628, finding insufficient evidence to support impeachment.[34]

McFadden's attempt

Rep. Louis Thomas McFadden's attempt to impeach numerous officials in May 1933[25] is detailed above.

Gonzalez's attempt

On March 7, 1985, Rep. Henry Gonzalez introduced an impeachment resolution, H.R. Res. 101, against Fed Chairman Paul Volcker and ten other members of the Federal Open Market Committee and H.R. Res. 102, against Volcker alone.The resolution was referred to the Judiciary Committee.,[35] where it was never heard of again. However, not to be deterred, Gonzalez introduced the bill in each of the next two congresses, and they met the same fate.

Other officials

Henry A. Smythe -- Collector, Port of New York

On March 22, 1867, three resolutions were introduced calling for various types of action against the allegedly corrupt Henry A. Smythe. Rep. Hulburd introduced a resolution calling for the President to remove Smythe from office.[36]). Mr. Stevens offered an impeachment resolution against Smythe and called upon the Committee on Public Expenditures to draft articles of impeachment. Id. Finally, Rep.Samuel Shellabarger of Ohio introduced a resolution requesting the Committee on Public Expenditures investigate Smythe's conduct.[37]

The next day, the House resumed debate over these three resolutions. A different resolution was ultimately adopted which did not call for Smythe's impeachment, but rather his immediate removal from office by the President. A copy of the resolution was sent to President Andrew Johnson,[38] who ignored it. Smythe left office in 1869 with the change in administration.

Charles Francis Adams, Ambassador to the Court of St. James, and William E. West, American Consul at Dublin

On December 2, 1867, Rep. William E. Robinson of New York introduced a resolution to investigate Charles Francis Adams, Sr. and William E. West, and why they hadn't tried to get some American citizens out of jail there.[39] The resolution was then referred to the Foreign Relations Committee,[40] where it died.

Oliver B. Bradford, consular clerk of the United States, assigned to Shanghai, China, and postal agent of the United States there

in a resolution introduced by Rep. William M. Springer, of Illinois, Bradford was accused of fraud, embezzelment and numerous other charges in relation to the building of a Cross China railroad. While all agreed it was criminal, it wasn't agreed whether or not the office was high enough to warrant impeachment.

George F. Seward, Minister plenipotentiary to China

On March 3, 1879, as part of the regular order of business was the report of the Committee on Expenditures in the State Department, Rep Springer proposed articles of impeachment against George F. Seward for bribery and theft. The articles were sent to the Judiciary committee, where they died.

Lot Wright, United States marshal

On December 2, 1884 Rep. John F. Follett, of Ohio introduced a point of privilege demanding that Wright be impeached for using armed deputies to fix an election. The proposition was held to be out of order.

Clarence Chase -- Collector of Customs, Port of El Paso, Texas

Chase was implicated in a Senate hearing before the Committee of Public Lands and Surveys as part of the Tea Pot Dome investigations. The Senate, on March 25, 1924, adopted a resolution, S. Res. 195, referring the matter to the House of Representatives for such proceedings as might be appropriate against Chase.[41] The resolution was referred to the Judiciary Committee.[42] The next day, Chase resigned from office, and no further action was taken by the House. Id. at 5009.

H. Snowden Marshall--U.S. District Atty., Southern District of NY

On December 14, 1915. Rep. Frank Buchanan of Illinois demanded the impeachment of H. Snowden Marshall, United States District Attorney for the Southern District of New York, for alleged neglect of duty and subservience to "the great criminal trusts," [43] The Chicago Tribune clamed it had been In an effort to stop the grand jury investigation into the activities of Labor's National Peace council.

About a month later, on Buchanan again offered a resolution, H.R. Res. 90, to investigate Marshall. This time the resolution was adopted and referred to the Judiciary Committee for further action.[44]

On January 27, 1916, the House passed a resolution, H.R. Res. 110, granting the Judiciary Committee authority to subpoena witnesses and to use a Subcommittee.[45] A few days later, a Subcommittee of the Judiciary Committee was organized to take testimony. On April 5, the HJC reported its findings, H.R. Rep. No. 64-494, to the House.. The Judiciary Committee recommended a Select Committee be appointed to further investigate Marshall. Rep. Kitchins offered a resolution, H.R. Res. 193, to adopt the Judiciary Committee's recommendations. The resolution passed and the Select Committee was formed.[46] The Select Committee report was read into the record on April 14.[47] The report found Marshall guilty of a breach of the privileges of the House and in contempt of the House of Representatives and recommended he be brought to the bar of the House to answer the charges.[48]

On June 20, a resolution, H.R. Res. 268, was submitted which charged Marshall with violating the privileges of the House of Representatives and calling the Speaker to issue a warrant for Marshall's arrest.[49] The resolution was adopted.[50] On June 22, the Speaker signed the warrant.[51]

When Marshall was arrested by the Sergeant at Arms on June 26, he served the Sergeant at Arms with a writ of habeas corpus.[52] The HJC voted to end the investigation on July 16. Marshall's writ eventually went to the United States Supreme Court where Chief Justice White issued the opinion of the court on April 23, 1917. The Court granted the writ and released Marshall from custody. [Marshall v. Gordon, 243 U.S. 521 (1916)].[53]

The Judiciary Committee submitted its last report, H.R. Rep. 64-1077, concerning impeachment efforts against Marshall on August 4, the report, which recommended against impeachment, was referred to the House Calendar.[54]

Phillip Forman -- U.S. Attorney for District of New Jersey

Fredrick Fenning -- Commissioner, District of Columbia

On April 19, 1926, articles of impeachment against Commissioner Frederick A. Fenning were read on the floor of the House, and a resolution, H.R. Res. 228, to investigate the validity of the charges was adopted. The resolution was referred to the Judiciary Committee.[55] On May 4, 1926, the Judiciary Committee submitted a report, H.R. Rep. No. 69-1075, recommending a complete investigation.[56] A resolution adopting the committee report was passed by the House on May 6, 1926.[57]

On June 9, 1926, Mr. Rankin submitted a brief to the investigating committee supporting Fenning's impeachment.[58] Then on June 16, 1926, after Fenning answered the charges, Mr. Rankin submitted a reply brief.[59]

Two committees were involved in the impeachment investigation of Fenning. A preliminary report of a Special Subcommittee of the Committee on the District of Columbia was submitted to the House on June 30, 1926.[60] Then on July 1, the final Judiciary Committee report, H.R. Rep. No. 69-1590, was submitted to the House and later referred to the House Calendar.[61] The proceedings ended with his resignation.

Liam S. Coonan, Special Crime Strike Force Prosecutor for the United States Department of Justice

On June 17, 1975, Rep William Clay introduced an impeachment resolution, H.R. Res. 547, against Liam S. Coonan, for doing something unspecified. It was sent to the HJC, where it died.

Richard Helms -- Ambassador to Iran

On July 29, 1975, Rep Robert Drinan introduced an impeachment resolution, H.R. Res. 647, against Ambassador Richard Helms for actions taken as Director of the CIA The resolution was referred to the Judiciary Committee.[62] When nothing happened, Fr. Drinan introduced another impeachment resolution, H.R. Res. 1105, against Ambassador Helms on March 24, 1976. This resolution was also sent to the Judiciary Committee.,[63] which also died there.

Jonathan Goldstein U.S. attorney for the District of New Jersey, and Bruce Goldstein, principal assistant DA

On Nov. 20, 1975, Rep Henry Helstoski introduced an impeachment resolution, H.R. Res. 881, against the Goldsteins, for gratuitous persecution in relation to their investigation of the congressman, which led to his indictment a month before. It was sent to the HJC, where it died.

Paul Rand Dixon, a Commissioner of the Federal Trade Commission

On February 9, 1977, Rep. Ed Koch and nine co-sponsors introduced H.R. Res. 274, against Paul Rand Dixon. The resolution was referred to the Judiciary Committee and vanished without a trace.

Andrew Young -- Ambassador to the United Nations

On October 3, 1977, Rep. Lawrence P. McDonald introduced an impeachment resolution, H.R. Res. 805, against Ambassador Andrew Young. The resolution was referred to the Judiciary Committee for action.[64]

Young had met secretly for meetings, in violation of American law, with representatives of the Palestine Liberation Organization, which culminated in Carter asking for Young's resignation.[65] Jimmy Carter denied any complicity in The Andrew Young Affair.

McDonald waited until July 13, 1978, to introduce a second impeachment resolution, H.R. Res. 1267, against him, and this time the resolution was tabled on the House floor.[66]

Kenneth W. Starr, an independent counsel of the United States appointed pursuant to 28 United States Code section 593(b)

On Sept.18, 1998 Rep. Alcee Hastings, who himself had been impeached, introduced H.RES.545 impeaching Kenneth Starr, whose investigation was leading to the impeachment of President Bill Clinton. Two days later, the House voted to table the bill 340 - 71.

Several weeks later, Hastings introduced H.RES.582, authorizing an investigation to see whether Starr should be impeached. This was referred to the Rules committee, which buried it.

References

  1. ^ Presidential Fact Book, by Joseph Nathan Kane (1999), pg. 67
  2. ^ The Presidents: A Reference History, edited by Henry F. Graff, 2nd edition (1996), pg. 148 (essay by Richard P. McCormick)
  3. ^ The Presidents: A Reference History, edited by Henry F. Graff, 2nd edition (1996), pg. 115 (essay by Richard B. Latner)
  4. ^ http://frwebgate.access.gpo.gov/cgi-bin/getdoc.cgi?dbname=hinds_prec_vol_iii&docid=f:hinds_lxiv.wais
  5. ^ Trefousse, 1989 pages 302–3
  6. ^ 76 Cong. Rec. 399 (1932).
  7. ^ CR Dec 13,1932 Louis T McFadden motion for impeachment of Herbert Hoover
  8. ^ 98 Cong. Rec. 4325, 4518 (1952)
  9. ^ 118 Cong. Rec. 16,350 (1972)
  10. ^ 119 Cong. Rec. 27,062 (1973).
  11. ^ 119 Cong. Rec. 34,871-73 (1973).
  12. ^ 120 Cong. Rec. 2349-50, 2362-63 (1974).
  13. ^ 137 Cong. Rec. 1736 (1991).
  14. ^ House Resolution 304, 105th Congress
  15. ^ Congressman Barr lowers the boom Insight on the News
  16. ^ 143 Cong. Rec. 10,105 (1997).
  17. ^ Cong. Globe, 42nd Cong., 3rd Sess. 1544 (1873).
  18. ^ 119 Cong. Rec. 31,368 (1973).
  19. ^ Hinds' Precedents, Volume III, Chapter LXXVII, section 2444, pp. 903-904
  20. ^ Ibid, section 2454, p. 922
  21. ^ Ibid, section 2459, p. 934
  22. ^ Ibid, section 2467, pp. 945-946
  23. ^ CR jan6,1932 Wright Patman motion for the impeachment of Andrew Mellon
  24. ^ "National Affairs: Texan, Texan & Texan". Time. January 25, 1932. http://www.time.com/time/magazine/article/0,9171,742975,00.html. Retrieved May 5, 2010. 
  25. ^ a b Congressional record - May 23, 1933 Pg 4055 - 4058
  26. ^ http://www.scribd.com/doc/4086334/McFaddens-Attempts-to-Abolish-the-Federal-Reserve-System
  27. ^ 84 Cong. Rec. 702 (1939)
  28. ^ Id. at 711.
  29. ^ 124 Cong. Rec. 2428 (1978)
  30. ^ Id. at 3486
  31. ^ ABC News: Dems Seek Gonzales Impeachment
  32. ^ 54 Cong. Rec. 3126 (1917)
  33. ^ congressional record 1917 pg 3126-3130
  34. ^ Id. at 4953.
  35. ^ 131 Cong. Rec. 5047 (1985)
  36. ^ Cong. Globe, 40th Cong., 1st Sess. 282 (1867
  37. ^ Id. at 284.
  38. ^ Id. at 289-90.
  39. ^ Cong. Globe, 40th Cong., 2nd Sess. 3 (1867).
  40. ^ Id. at 3-8.
  41. ^ 65 Cong. Rec. 4915 (1924).
  42. ^ Id. at 4992.
  43. ^ 53 Cong. Rec. 240 (1915)
  44. ^ Id. at 962-71.
  45. ^ Id. at 1658-59
  46. ^ Id. at 5540-41
  47. ^ Id. at 6135
  48. ^ Id. at 6141.
  49. ^ Id. at 9638
  50. ^ Id. at 9670
  51. ^ Id. at 9792
  52. ^ Id. at 10,371
  53. ^ http://caselaw.lp.findlaw.com/cgi-bin/getcase.pl?court=US&vol=243&invol=521
  54. ^ Id. at 12,096
  55. ^ 67 Cong. Rec. 7753, 7814 (1926)
  56. ^ 67 Cong. Rec. 8718 (1926)
  57. ^ Id. at 8822-28
  58. ^ Id. at 11,019
  59. ^ Id. at 11,374
  60. ^ Id. at 12,397
  61. ^ Id. at 12,593, 12,858
  62. ^ 121 Cong. Rec. 25,578, 25,599 (1975)
  63. ^ 122 Cong. Rec. 7830 (1976)
  64. ^ 123 Cong. Rec. 32,055 (1977)
  65. ^ Frum, David (2000). How We Got Here: The '70s. New York, New York: Basic Books. p. 272. ISBN 0-465-04195-7. 
  66. ^ .124 Cong. Rec. 20,607-09 (1978)