"No Confidence" Votes and Other Forms of Congressional Censure of Public Officials

Prepared for Members and Committees of Congress

S.J.Res. 14 of the 110th Congress, submitted on May 24, 2007, has been described as proposing a
vote of no confidence in Attorney General Alberto Gonzales. This report discusses the possible
significance of action by Congress or either House to adopt a resolution expressing “no
confidence” in a cabinet official or other official in the executive branch of the federal
government. It examines the legal issues that could be raised by resolutions of this kind and
discusses the relation of such action both to votes of no confidence in systems of parliamentary
government and to congressional action to censure or otherwise express disapprobation of public
officials. It also describes known instances in which action to express a lack of confidence in, or
impose another form of censure on, public officials have been attempted in Congress.

“No Confidence” Votes in a System of Separated Powers..............................................................1
Propriety of Congressional Censure of Public Officials..................................................................2
Relation to Other Forms of Congressional Action....................................................................3
Characteristics of Resolutions Proposed Since 1973......................................................................4
Terms of Disapprobation Used..................................................................................................4
Preambles .................................................................................................................................. 5
Inclusion of “Sense” Language.................................................................................................5
Form of Measure.......................................................................................................................5
Legislative Action.....................................................................................................................5
Examples of Earlier Resolutions.....................................................................................................6
Censure and Condemnation......................................................................................................6
Resignation and No Confidence................................................................................................7
Concluding Observations................................................................................................................8
Appendix. Congressional Resolutions Expressing Disapprobation of Executive Branch
Officials, 1973-2006.....................................................................................................................9
Author Contact Information..........................................................................................................12

.J.Res. 14 of the 110th Congress, submitted on May 24, 2007, has been described as
proposing a vote of no confidence in Attorney General Alberto Gonzales. This report
discusses the possible significance of action by Congress or either House to adopt a S

resolution expressing “no confidence” in a cabinet official or other official in the executive
branch of the federal government. It examines the legal issues that could be raised by resolutions
of this kind and discusses the relation of such action both to votes of no confidence in systems of
parliamentary government and to congressional action to censure or otherwise express
disapprobation of public officials. It also describes known instances in which action to express a
lack of confidence in, or impose another form of censure on, public officials have been attempted
in Congress.

The use of the term “vote of no confidence” to reflect a Senate, House or joint congressional
action on a resolution concerning an official of the executive branch might be somewhat
misleading because of the particular nature and impact of “no confidence” votes in parliamentary
democracies. A vote of no confidence has a technical meaning and concrete consequences only in
a parliamentary form of government, in which the continuance of the executive in office is
dependent on its maintaining majority support in the parliament (or one house thereof). The
American system of separated powers, on the other hand, makes no provision for votes of no
confidence in the parliamentary sense. Except through the process of impeachment, accordingly,
no action by the Congress (or of either House) can have any practical effect similar to that of a
parliamentary vote of no confidence.
For example, votes of “no confidence” or “votes of censure” in the British Parliament,1 are votes
instituted in Parliament by the opposition party which, if they succeed, indicate that the
Government no longer has the support of the majority of Parliament (including the Government’s 2
own party members), and thus lead to a dissolution of the Government and new elections. Under
the U.S. system of government, with the constitutional scheme of separated powers, the
legislature—Congress—does not impact directly the removal of officials in the executive branch
of the Federal Government (other than through impeachments). Adoption of a resolution
expressing a lack of confidence could have symbolic effects as an expression of the sense of
Congress (or of either House). A vote expressing “no confidence” of the Senate or the House in a
particular official of the government, while it may certainly have political implications, would
have no specific legal import.

1 Although the phrasevote of no confidence” is generally used in the United States to describe the process, in
England, the completed vote on a motion introduced by the opposition is referred to as avote of censure.”
2 Erskine May’s Treatise on the Law, Privileges, Proceedings and Usage of Parliament, Twenty-second edition (Sir
Donald Limon and W.R. McKay, editors), at pp. 280-281 (1997). See William Safire, Safires Political Dictionary, at
768 (1978): “[I]f a motion of no confidence is introduced by the opposition in the House of Commons and passes, the
result is called a vote of censure (although it contains the words “no confidence, it is not referred to as a vote of no
confidence, except in America); in that case, the government is ‘upset’ or ‘falls, and an election is called.

The issue of the propriety and the authority of Congress or of either House of Congress to
officially express an opinion concerning an executive branch officer, such as an opinion that the
President should remove an official, or that a cabinet official should resign, or to otherwise
formally reprimand, “censure,” or express disapprobation or loss of confidence concerning an
executive official has been debated and questioned from time to time in the House and the 3
Senate. In early congressional considerations some Members of Congress, in their opposition to
resolutions which declared either an opinion of praise or disapproval of the executive, cited the
lack of an express constitutional grant of authority for the House or the Senate to state an opinion
on the conduct or propriety of an executive officer in the form of a formal resolution of censure or 4
disapproval. Others have argued, including during the more recent consideration of the
impeachment of President Clinton, that impeachment was the proper, and exclusive,
constitutional response for Congress to entertain when the conduct of federal civil officers is 5
called into question, rather than a resolution of censure. Concerning judicial officers, precedents
indicate that the House has on occasion either rejected or not dealt with attempts to consider a
“censure” motion of federal judges offered by the Judiciary Committee as an alternative to
articles of impeachment, and parliamentarians have noted an apparent disinclination of the House 6
to consider censure as part of the impeachment procedure.
It has, however, become accepted congressional practice to employ a simple resolution of one
House of Congress, or a concurrent resolution by both Houses, for certain non-legislative matters,
such as to express the opinion or the sense of the Congress or of one House of Congress on a
public matter, and a resolution expressing an opinion of “no confidence” in, or other expression
of censure or disapproval of an executive branch official within a concurrent or simple resolution

3 II Hinds’ Precedents of the House of Representatives [Hinds’ Precedents], §1569, p. 1029 (1907): “While the House
in some cases has bestowed praise or censure on the President or a member of his Cabinet, such action has at other
times been held to be improper.
4 II Hinds’ Precedents, at §1569, pp. 1029-1030: “It was objected that the Constitution did not include such expressions
of opinion among the duties of the House ....” (Citing debate and vote on a resolution of approval of the President’s thnd
conduct, which was laid on the table, 20 Annals of the Congress, 11 Cong., 2 Sess., at 92 -118, 134-151, 156-161,
164-182, 187-217, 219 (1809)).
5 Note discussion of a House resolution in 1867 expressing opinion on the unfitness for the office of Mr. Henry Smyth
(II Hinds’ Precedents, at §1581, pp. 1035-1036), and a 1924 Senate resolution indicating its sense that the President thst
“immediately request the resignation of the Secretary of Navy. 65 Congressional Record, 68 Cong., 1 Sess., 2223-
2245 (1924). Both of these resolutions were objected to by some Members as interfering with the President’s
prerogatives in appointments and removals of executive officials, and the latter action as labeling with abrand of
shame an individual in the Government without conducting impeachment proceedings. See discussion in Fisher,
“Congress and the Removal Power,” in Congress & the Presidency, Volume 10, at 67-68 (1983). Concerning the
impeachment of President Clinton, see discussions inCensure Option Losing Support in House, The Hill, September
16, 1998; “Senators Exploring a Form of Censure Are Bumping Into Obstacles,” Washington Post, January 2, 1999.
6 The censure of U.S. District Court Judge Harold Louderback, recommended in a Judiciary Committee report in 1933
instead of impeachment, was objected to, for example, by Rep. Earl Michener of Michigan, who explained: “I do not
believe that the constitutional power of impeachment includes censure. The recommendation was not approved, and
the House adopted as a substitute an amendment impeaching the judge. 3 Deschler’s Precedents of the U.S. House of
Representatives [Deschler’s Precedents], Ch. 14, §1.3, p. 400 (1977). In other instances recommendations of censure of
judges, as alternatives to impeachment, were made by the Judiciary Committee, but not acted on by the House. Id. at
400-401; III Hind’s Precedents, supra at §§ 2519, 2520.

would appear to be in the nature of such a “sense of Congress” or “sense of the Senate” (or 7
House) resolution. The absence of express constitutional language that the Congress, or the
House or the Senate individually, may state its opinion on matters of public import in a resolution
of praise or censure is not necessarily indicative of a lack of capacity to do so, or that such
practice is per se unconstitutional. It is recognized in both constitutional law and governmental
theory that there are, of course, a number of functions and activities of Congress which are not
expressly stated or provided in the Constitution, but which are nonetheless valid as either inherent
or implied components of the legislative process or of other express provisions in the
Constitution, or are considered to be within the internal authority of democratic legislative 8
institutions and elective deliberative bodies generally. The practice of the House, Senate, or
Congress to express facts or opinion in simple or concurrent resolutions has been recognized
since its earliest days as an inherent authority of the Congress and of democratic legislative
institutions generally, and the adoption of “sense of” the House or Senate resolutions on various 9
subjects and in reference to various people, is practiced with some frequency in every Congress.
The resolutions or statements both the House and the Senate have adopted in the past concerning
a Government official, other than a Member of Congress, have expressed disapproval, censure, or
opinion that an officer should be removed, Such an expression of opinion, censure, disapproval or
lack of confidence in or of a federal officer by the House, the Senate, or the Congress is not an
“impeachment” of that civil officer under Article I, Section 2, clause 5 and Section 3, clause 6 of 10
the Constitution; nor is it a “punishment” of one of the House’s or Senate’s own Members under
Article I, Section 5, clause 2.
Furthermore, a censure or vote of no confidence would also not, in most cases, be within those
inherent or implicit authorities, in the nature of contempt, typically imputed to democratic
legislative assemblies to protect the dignity and integrity of the institution, its members and 11
proceedings. Finally, because there is no legal consequence to a resolution expressing an

7Simple resolutions are used in dealing with nonlegislative matters such as expressing opinions or facts .... Except as
specifically provided by law, they have no legal effect, and require no action by the other House. Containing no
legislative provisions, they are not presented to the President of the United States for his approval, as in the case of bills
and joint resolutions.” 7 Deschler’s Precedents, Ch. 24, § 6.[Concurrent resolutions] are not used in the adoption of
general legislation. ... [They] are used in ... expressing the sense of Congress on propositions .... A concurrent
resolution does not involve an exercise of the legislative power under article I of the Constitution in which the thst
President must participate. Id. at § 5. Brown, House Practice, 108 Congress, 1 Sess., at 168: “Simple or concurrent
resolutions are used ... to express facts or opinions, or to dispose of some other nonlegislative matter. See also Riddick
& Frumin, Riddicks Senate Procedure, 1202 (1992).
8 The most common example of inherent or implied authority of Congress is the oversight and investigatory authority
of either House, including the power to compel attendance of witnesses and production of documents. Such authority is
not expressly provided in the Constitution, but the ability to collect facts and opinions, and to publish such opinions and
facts, are considered inherent in the authority to legislate. McGrain v. Daugherty, 272 U.S. 135 (1927); Watkins v.
United States, 354 U.S. 178, 187, 200 (1957).
9 See note 9, supra; Cushing, at 314. In the 105th Congress, for example, the House unanimously adopted a resolution
to “condemn as a “racist act” the alleged actions of three expressly named individuals in Texas who were arrested in th
connection with what is reported as a racially motivated homicide (H.Res. 466, 105 Cong ).
10 See 3 Deschler’s Precedents, Ch. 14, § 1.
11 As to inherent contempt authority, see Anderson v. Dunn, 19 U.S. 204 (1821). Note, generally, Cushing, Elements of
the Law and Practice of Legislative Assemblies in the United States of America [Cushing], 245-255, 255-272 (1856).
Since such action does not bear upon the proceedings and privileges of the House, and is not part of impeachment, such

opinion of the Senate or the House, and because such expression in a simple resolution does not
appear to technically be a “bill” referred to in the constitutional prohibition on “bills of attainder,” 12
it is unlikely that such an expression would violate that constitutional restriction on Congress.

These resolutions, expressing the disapproval of Congress (or of either house) with an official of 13
the executive branch, have in the past sometimes been submitted, and occasionally adopted. For
recent years, it has been possible to identify resolutions of this kind systematically through a
search of the Legislative Information System of the Congress (LIS), which includes a database of rd
introduced measures extending back to the 93 Congress (1973-1974). An initial search identified
simple and concurrent resolutions described with any form of the terms “confidence,” “censure,”
or “condemnation.” On the basis of information independently acquired about resolutions offered
in the early 1950s against Secretary of State Dean Acheson, the search was also was extended to
include simple and concurrent resolutions described with any form of the term “resignation.”
From among the measures identified by these searches, those relating to federal officials other 14
than Members of Congress were selected. These searches together yielded 31 resolutions rdth
submitted from the 93 through 109 Congresses (1973-2006) and directed against federal
officials. Information about the subject and form of these 31 measures is presented in Appendix.
It appears that such resolutions have been stated not usually in terms of no confidence, but more
often in terms of censure or condemnation, or as calls for resignation. Of the 31 resolutions
identified by the search, 13 expressed censure of the official, condemnation of the official or his
or her actions, or both. The remaining 18 resolutions called either for the official in question to
resign or for the President to request resignation, making this form of disapproval the most
common among measures identified from recent times.
Only one of the 31 resolutions referred explicitly to a loss of confidence, and this language was
contained only in the preamble of a resolution that also called for resignation. Although the term
“no confidence” was not necessarily expressly stated in nearly all of these resolutions, however,
such opinion was obviously implied by the actual wording of a number of the resolutions.
Previous to S.J.Res. 14, nevertheless, no resolution known in recent times has stated only a loss
of confidence, unaccompanied by reference to any other form of disapprobation. The use solely
of this language might suggest a lack of awareness that the reference to a loss of confidence, in

a resolution would generally not be considered to be a privileged resolution. See 3 Deschler’s Precedents, Chapter 14,
§ 1, p. 401.
12 Article I, Section 9, clause 3. See Nixon v. Administrator of General Services, 433 U.S. 425, 468 (1977); note
definition ofbill” in 7 Deschler’s Precedents, Ch. 24, § 2. For a discussion of these legal issues, and separation of
powers considerations, see CRS Report 98-843, Censure of the President by the Congress, by Jack Maskell.
13 For examples, see archived CRS Report 98-983 GOV, Censure of Executive and Judicial Branch Officials: Past
Congressional Proceedings, by Richard S. Beth (available from the author).
14 One of the resolutions included proposes to censure a former official for acts subsequent to leaving office; it was
included in the analysis on the principle that borderline cases were better taken into consideration than ignored.

the American context, lacks any distinctive or special force not shared by other terms in which
resolutions with similar prospective effects have been couched. The use of “no confidence”
language would not suffice actually to endow the proposal uniquely with any such distinctive or
special force.
Most of the resolutions identified that were submitted in or after 1973 have included a preamble
stating the reasons for the congressional disapproval. Of the total of 31, just three lacked such a
preamble. The current S.J.Res. 14, which also lacks a preamble, accordingly represents a less
common variation.
Similarly, 16 of the 31 resolutions identified by electronic search explicitly declared themselves
to be statements of the sense of the Congress or of the house acting (usually in those terms,
though a few refer instead to the “sentiment” or “judgment” of Congress or either house). This
form of language again appears consistent with an understanding that any such measure could
have symbolic, rather than determinative, effects. This language appears to have been included in th
measures of this kind less frequently since 1996 (105 Congress), but is adopted by S.J.Res. 14.
All 31 of the resolutions identified through the electronic search were either concurrent
resolutions or simple resolutions of one house. No search was conducted for joint resolutions,
because of the inappropriateness of this form of measure to the kind of action possible in the
American system. For this reason, no conclusion can be offered about whether any earlier
measures to express disapproval of a federal official have taken the form of a joint resolution.
Use of simple and concurrent resolutions suggests awareness that adoption of such a measure
would have no imperative force parallel to that of a vote of no confidence in a parliamentary
system. By contrast, even though the language of S.J.Res. 14 explicitly disavows any mandatory
intent, by stating itself as an expression of the sense of the Senate, the measure is couched as a
joint resolution. Joint resolutions are normally lawmaking vehicles, and require passage by both
chambers and presentation to the President. It is not clear what proponents intend by submitting
the measure in this form, which would have the effect of affording the House of Representatives
and the President a role in stating what the sense of the Senate is. It is conceivable that the use of
this form of measure in the current case implicitly indicates an intent to achieve effects
resembling those of an actual vote of no confidence.
Congress did not finally adopt any of the 31 resolutions identified in the present search, and on th
none but two did any floor action occur at all. In 1997 (105 Congress), the House adopted
H.Con.Res. 197, declaring that Sara A. Lister, Assistant Secretary of the Army for Manpower and th
Reserve Affairs, should resign or be removed. In 1999 (106 Congress), the Senate rejected an
attempt to bring to the floor S.Res. 44, censuring President Clinton.

No feasible means appeared of comprehensively identifying similar measures for the period
preceding the availability of electronically searchable data. In the historical period before that
covered by the LIS database, nevertheless, several instances are known in which the House or the
Senate expressed a specific opinion disapproving of conduct of an executive official, or 15
suggesting that a particular executive officer resign or be removed by the President.
The instances discussed in this section constitute only examples of congressional actions; they are
known not to compose a comprehensive list of all resolutions to censure executive (and judicial)
officials that may have been adopted or considered by either House. Accordingly, available
information can permit no definite assertion whether a vote of no confidence fully similar to that
proposed by S.J.Res. 14 has ever previously occurred in American history. It might be considered
unlikely, however, that resolutions critical of officials during earlier periods of history would have
been couched solely in terms of “no confidence,” because proponents would likely have
understood that these terms have a technical meaning only in a parliamentary system of
The earliest attempt to censure an official found thus far concerned a series of resolutions
proposing the censure and disapproval of Secretary Alexander Hamilton in 1793, the texts of
which were considered by historians to have been drafted by Thomas Jefferson for introduction 16
by Representative William Branch Giles of Virginia.
In 1860, the House of Representatives adopted a resolution stating that the conduct of the
President, and his Secretary of the Navy, was deserving of its “reproof,” in a matter concerning
the alleged conduct of President Buchanan and his Secretary of the Navy in allowing political
considerations and alleged campaign contribution “kickbacks” to influence the letting of 17
Government contracts to political supporters, rather than the lowest bidder. After debating both
the substance of the charges and the authority of the House to adopt such a resolution,
characterized by one Member as “censur[ing] indiscriminately the President of the United States 1819
and the Secretary of Navy,” the House adopted the resolution 106-61.

15 The examples discussed in the section onCensure and Condemnation” are drawn from CRS Report 98-983,
“Censure of Executive and Judicial Branch Officials: Past Congressional Proceedings, by Richard S. Beth (archived,
available from the author).
16 Sheridan, Eugene R., “Thomas Jefferson and the Giles Resolutions,” William and Mary Quarterly, Third Series,
Volume 49, Issue 4, at 589-608 (October 1992). The resolutions did not pass.
17 Resolved, That the President and Secretary of the Navy, by receiving and considering the party relations of bidders
for contracts with the United States, and the effect of awarding contracts upon pending elections, have set an example thst
dangerous to the public safety, and deserving the reproof of this House. Congressional Globe, 36 Congress, 1 Sess.,
2951 (June 13, 1860).
18 Id. at 2951. (Mr. Clark of Missouri).
19 Id., at 2951.

The Senate adopted a resolution in 1886 in which it expressed its “condemnation” of President
Cleveland’s Attorney General A.H. Garland concerning his refusal to provide certain records and 20
papers to the Senate about the removal from office of a district attorney by the President.
In 1896, the House adopted a resolution where it found that a United States Ambassador, by his
speech and conduct “has committed an offense against diplomatic propriety and an abuse of the
privileges of his exalted position,” and therefore, “as the immediate representatives of the
American people, and in their names, we condemn and censure the said utterances of Thomas F. 21
Some congressional resolutions over the years have merely found misconduct on the part of an
executive officer and urged the President to seek the officer’s resignation, without expressing a
specific term of censure or condemnation, or a specific expression of loss of “confidence.” For
example, after having conducted investigations into the conduct of the administration of the New
York custom-house by Mr. Henry Smyth, and finding that “there is not sufficient time prior” to
adjournment to finish the matter, the House expressed in a resolution “Henry A. Smyth’s
unfitness to hold the office,” and recommended that he “should be removed from the office of 22
coll ector.”
Similarly, the Senate in 1924, during the Teapot Dome investigation passed a resolution
indicating its sense that the President “immediately request the resignation” of the Secretary of 23
In the 81st and 82nd Congresses (1949-1952), six resolutions were submitted containing demands
for the resignation of Secretary of State Dean Acheson, and one seeking that of Secretary of
Defense George C. Marshall. All of these resolutions, unlike many more recent measures, lacked
preambles setting forth the reasons for the action. These measures provide one of the few earlier
instances known that were described as proposing votes of no confidence in the respective
officials. Three of the seven resolutions explicitly stated a popular loss of confidence along with
(but not instead of) the calls for resignation (although one, like the 1983 instance discussed
earlier, did so only in the preamble). Several of these resolutions, apparently including those
whose text did not contain this explicit phrase, were also described, in public discussion, as
declarations of no confidence. Finally, during the same time period, a loss of public confidence in
Secretary Acheson was declared by votes of the Republican Conference in at least one chamber.
These events illustrate that a resolution may be described as a “no confidence” measure without
having the characteristics that would make it equivalent to an actual vote of no confidence in a
parliamentary system.

20 17 Congressional Record, 49th Cong., 1st Sess., pp. 1584-1591, 2784-2810 (March 26, 1886):Resolved, That the
Senate hereby expresses its condemnation of the refusal of the Attorney-General, under whatever influence, to send to th
the Senate copies of papers called for by its resolution of the 25 of January, and set forth in the report of the
Committee on the Judiciary, is in violation of his official duty and subversive of the fundamental principles of the
Government and of a good administration thereof.
21 28 Congressional Record, 54th Cong., 1st Sess., p. 3034 (March 20, 1896).
22 Congressional Globe, 40th Cong., 1st Sess., pp. 255-256, 282-285, 394-395 (1867).
23 65 Congressional Record, 68th Cong., 1st Sess., 2223-2245 (February 11, 1924).

Although there has been discussion in both Houses of Congress of the appropriateness of such
actions, resolutions have been introduced and considered in each House of Congress in the past,
and on occasion have been adopted, wherein the House or the Senate has expressed the “sense” of
the institution that an official in the executive branch has engaged in conduct worthy of censure,
condemnation, or other expression of disapprobation; should resign or be removed by the
President; and, in a few circumstances, expressly stating in the preamble or the operative portion
of the resolution that the public or the particular House of Congress has lost “confidence” in the
official. Such actions and proposals would appear to be in the nature of “sense of Congress” or
“sense of the Senate” (or House) resolutions in which it has been the practice for the Senate or the
House to address certain non-legislative matters, such as to express the opinion or the sense of 24
Congress or of one House of Congress on a public matter. Aside from obvious symbolic,
political or publicity implications, there are no specific legal consequences in the passage of such
a resolution, nor is there any legal significance or consequence for the Senate or the House to
choose one phrase of disapprobation or condemnation over another, or to include or not to include
the concept or expression of a loss of “confidence” in an official.
Several features of S.J.Res. 14 seem to make explicit its difference from an actual “vote of no
confidence” such as could occur in a parliamentary system, but others suggest a failure to take
account of that difference. To the extent that the resolution purports to present a proposition
functionally similar to a vote of no confidence in a parliamentary system, present knowledge does
not permit identifying any similar proposition as having been offered in the past. On the other
hand, to the extent that the present resolution purports to present such a proposition, it cannot,
under the American constitutional system, succeed in doing so. Instead, the proposition actually
presented by the resolution can only be that of expressing congressional disapproval of a federal
official, and in that general respect the resolution is not dissimilar from a number of others that
have been offered, from time to time, throughout American history.

24 7 Deschler’s Precedents, Ch. 24, § 6; Riddick & Frumin, Riddicks Senate Procedure, 1202 (1992).

Provisions on Measure Number Notes and
Congress and Date of Official Framing Loss of (in italics)
Introduction Confidence Resignation Censure Floor Action
93 H.Con.Res. 371 President Preamble; Censure Each resolution also states that
10/20/1973 Richard M. Nixon sense of this action carries no prejudice to
Congress impeachment
93 H.Con.Res. 365 President Preamble; Censure,
10/23/1973 Richard M. Nixon sense of condemn
93 S.Res. 191 Solicitor General Preamble In title:
10/23/1973 (Acting Attorney General) censure; in
iki/CRS-RL34037Robert Bork body: condemn
s.or93 H.Con.Res. 376 President Preamble; Should resign
leak11/7/1973 Richard M. Nixon sense of
://wiki93 H.Res. 684 President Preamble; Should resign Identical resolutions also ask that
http11/6/1973 Richard M. Nixon Judgment of Nixon first nominate someone
House other than Gerald Ford to be
93 H.Res. 734 President Preamble; Should resign Vice President
12/4/1973 Richard M. Nixon Judgment of
93 H.Res. 1288 President Preamble Censure
8/4/1974 Richard M. Nixon
93 H.Con.Res. 589 President Preamble; Censure Also sense of Congress that if
8/6/1974 Richard M. Nixon sense of Nixon resigns, impeachment not
Congress be pursued
96 H.Con.Res. 146 Secretary of Energy Should resign
6/26/1979 James Schlesinger
96 H.Con.Res. 161 Secretary of Energy Preamble Should resign

7/12/1979 James Schlesinger

Provisions on Measure Number Notes and
Congress and Date of Official Framing Loss of (in italics)
Introduction Confidence Resignation Censure Floor Action
97 H.Con.Res. 242 Environmental Protection Preamble; Should resign
12/16/1981 Agency Director Anne sense of
Gorsuch Congress
97 H.Con.Res. 247 Federal Reserve Board Preamble; Should resign
1/26/1982 Chairman Paul Volcker sense of
98 H.Res. 321 Secretary of the Interior Sense of President
9/28/1983 James Watt House should ask
98 H.Res. 324 Secretary of the Interior Preamble; in preamble: President
9/29/1983 James Watt sense of people lost should ask
98 H.Con.Res. 249 Secretary of Defense Sense of Should resign
iki/CRS-RL340372/2/1984 Caspar Weinberger Congress
g/w103 H.Res. 545 Surgeon General Preamble; President
s.or9/23/1994 Jocelyn Elders sense of should ask
103 H.Con.Res. 297 Surgeon General Preamble; President
://wiki9/26/1994 Jocelyn Elders sense of should ask
104 H.Res. 283 Secretary of Energy Preamble; President Also provisions on
11/28/1995 Hazel O’Leary sense of should ask reimbursement
104 H.Res. 308 Secretary of Energy Preamble; President Also provisions on investigation
12/15/1995 Hazel O’Leary sense of should ask and reimbursement
105 H.Con.Res. 197 Assistant Secretary of the Preamble Should resign or House adopted, 11/13/1997
11/13/1997 Army for Manpower and be removed
Reserve Affairs Sara E.
105 H.Res. 531 President William Preamble House calls

9/11/1998 Jefferson Clinton upon to resign

Provisions on Measure Number Notes and
Congress and Date of Official Framing Loss of (in italics)
Introduction Confidence Resignation Censure Floor Action
106 S.Res. 44 2/12/1999 President William Preamble Censure; Senate rejected attempt to bring to
Jefferson Clinton condemn floor, 2/12/1999
106 H.Res. 416 2/7/2000 U.S. District Judge Preamble Condemn
Alan McDonald conduct
108 H.Res. 419 Deputy Undersecretary of Preamble President
10/28/2003 Defense Lieutenant General should
William Boykin censure
108 H.Res. 420 Deputy Undersecretary of Preamble Condemn
10/28/2003 Defense Lieutenant General rhetoric
William Boykin
108 H.Con.Res. 323 Secretary of Defense Preamble President
iki/CRS-RL3403711/7/2003 Donald Rumsfeld should ask
g/w109 H.Con.Res. 470 Secretary of Defense Preamble; effect “Replace” in title; not found by
s.or9/13/2006 Donald Rumsfeld sense of resignation search
109 S.Res. 262 9/30/2005 former Secretary of Preamble Condemn
://wikiEducation William J. Bennett statement
http109 H.Res. 636 President Preamble Censure
12/18/2005 George W. Bush
109 H.Res. 637 Vice President Preamble Censure
12/18/2005 Richard B. Cheney
109 S.Res. 398 3/13/2006 President Preamble Censure;
George W. Bush condemn
Source: Legislative Information System of the U.S. Congress; Congressional Record.

Jack Maskell Richard S. Beth
Legislative Attorney Specialist on the Congress and Legislative Process
jmaskell@crs.loc.gov, 7-6972 rbeth@crs.loc.gov, 7-8667