[House Hearing, 119 Congress]
[From the U.S. Government Publishing Office]


                    LEGISLATIVE REFORMS TO END LAWFARE BY 
                        STATE AND LOCAL PROSECUTORS

=======================================================================

                                HEARING

                               BEFORE THE

                   SUBCOMMITTEE ON THE CONSTITUTION AND 
                             LIMITED GOVERNMENT

                                 OF THE

                       COMMITTEE ON THE JUDICIARY

                     U.S. HOUSE OF REPRESENTATIVES

                    ONE HUNDRED NINETEENTH CONGRESS

                             FIRST SESSION

                               __________

                         TUESDAY, MARCH 4, 2025

                               __________

                           Serial No. 119-10

                               __________

         Printed for the use of the Committee on the Judiciary
         
[GRAPHIC NOT AVAILABLE IN TIFF FORMAT]         


               Available via: http://judiciary.house.gov
               
                                __________

                   U.S. GOVERNMENT PUBLISHING OFFICE                    
59-556                    WASHINGTON : 2025                  
          
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                       COMMITTEE ON THE JUDICIARY

                        JIM JORDAN, Ohio, Chair

DARRELL ISSA, California             JAMIE RASKIN, Maryland, Ranking 
ANDY BIGGS, Arizona                      Member
TOM McCLINTOCK, California           JERROLD NADLER, New York
THOMAS P. TIFFANY, Wisconsin         ZOE LOFGREN, California
THOMAS MASSIE, Kentucky              STEVE COHEN, Tennessee
CHIP ROY, Texas                      HENRY C. ``HANK'' JOHNSON, Jr., 
SCOTT FITZGERALD, Wisconsin              Georgia
BEN CLINE, Virginia                  ERIC SWALWELL, California
LANCE GOODEN, Texas                  TED LIEU, California
JEFFERSON VAN DREW, New Jersey       PRAMILA JAYAPAL, Washington
TROY E. NEHLS, Texas                 J. LUIS CORREA, California
BARRY MOORE, Alabama                 MARY GAY SCANLON, Pennsylvania
KEVIN KILEY, California              JOE NEGUSE, Colorado
HARRIET M. HAGEMAN, Wyoming          LUCY McBATH, Georgia
LAUREL M. LEE, Florida               DEBORAH K. ROSS, North Carolina
WESLEY HUNT, Texas                   BECCA BALINT, Vermont
RUSSELL FRY, South Carolina          JESUS G. ``CHUY'' GARCIA, Illinois
GLENN GROTHMAN, Wisconsin            SYDNEY KAMLAGER-DOVE, California
BRAD KNOTT, North Carolina           JARED MOSKOWITZ, Florida
MARK HARRIS, North Carolina          DANIEL S. GOLDMAN, New York
ROBERT F. ONDER, Jr., Missouri       JASMINE CROCKETT, Texas
DEREK SCHMIDT, Kansas
BRANDON GILL, Texas
MICHAEL BAUMGARTNER, Washington

                                 ------                                

        SUBCOMMITTEE ON THE CONSTITUTION AND LIMITED GOVERNMENT

                         CHIP ROY, Texas, Chair

TOM McCLINTOCK, California           MARY GAY SCANLON, Pennsylvania, 
THOMAS MASSIE, Kentucky                  Ranking Member
HARRIET HAGEMAN, Wyoming             STEVE COHEN, Tennessee
WESLEY HUNT, Texas                   PRAMILA JAYAPAL, Washington
GLENN GROTHMAN, Wisconsin            JOE NEGUSE, Colorado
MARK HARRIS, North Carolina          BECCA BALINT, Vermont
ROBERT F. ONDER, Jr., Missouri       SYDNEY KAMLAGER-DOVE, California
BRANDON GILL, Texas                  DANIEL S. GOLDMAN, New York

               CHRISTOPHER HIXON, Majority Staff Director
                  JULIE TAGEN, Minority Staff Director
                           
                           
                           C O N T E N T S

                              ----------                              

                         Tuesday, March 4, 2025
                           
                           OPENING STATEMENTS

                                                                   Page
The Honorable Chip Roy, Chair of the Subcommittee on the 
  Constitution and Limited Government from the State of Texas....     1
The Honorable Mary Gay Scanlon, Ranking Member of the 
  Subcommittee on the Constitution and Limited Government from 
  the State of Pennsylvania......................................     3
The Honorable Jim Jordan, Chair of the Committee on the Judiciary 
  from the State of Ohio.........................................     6
The Honorable Jamie Raskin, Ranking Member of the Committee on 
  the Judiciary from the State of Maryland.......................     7

                               WITNESSES

The Honorable George J. Terwilliger, Terwilliger Law PLLC
  Oral Testimony.................................................    10
  Prepared Testimony.............................................    12
Daniel Z. Epstein, America First Legal
  Oral Testimony.................................................    21
  Prepared Testimony.............................................    23
Elizabeth Price Foley, BakerHostetler, LLP
  Oral Testimony.................................................    32
  Prepared Testimony.............................................    34
Elizabeth Earle Beske, Professor of Law, American University 
  Washington College of Law
  Oral Testimony.................................................    45
  Prepared Testimony.............................................    47

          LETTERS, STATEMENTS, ETC. SUBMITTED FOR THE HEARING

All materials submitted by the Subcommittee on the Constitution 
  and Limited Government, for the record.........................    85

Materials submitted by the Honorable Mary Gay Scanlon, Ranking 
  Member of the Subcommittee on the Constitution and Limited 
  Government from the State of Pennsylvania, for the record
    An excerpt from a Transcribed Interview of Steven D'Antuono, 
        pgs. 15-16, Jun. 7, 2023
    An excerpt from a Transcribed Interview of Steven D'Antuono, 
        pgs. 74-77, Jun. 7, 2023
    An article entitled, ``U.S. Attorney Rebuffed by Justice 
        Dept. in Push to Escalate Inquiry Into Schumer,'' Mar. 3, 
        2025, Washington Post
Materials submitted by the Honorable Daniel S. Goldman, a Member 
  of the Subcommittee on the Constitution and Limited Government 
  from the State of New York, for the record
    An article entitled, ``U.S. Attorney Rebuffed by Justice 
        Dept. in Push to Escalate Inquiry Into Schumer,'' Mar. 
        14, 2025, The New York Times
    A letter to the Inspector General Horowitz from Members of 
        Congress, Feb. 12, 2025
An article entitled, ``Who has Donald Trump threatened to 
  prosecute as president?'' Jan. 20, 2025, Reuters, submitted by 
  the Honorable Jamie Raskin, Ranking Member of the Committee on 
  the Judiciary from the State of Maryland, for the record

 
   LEGISLATIVE REFORMS TO END LAWFARE BY STATE AND LOCAL PROSECUTORS

                              ----------                              


                         Tuesday, March 4, 2025

                        House of Representatives

        Subcommittee on the Constitution and Limited Government

                       Committee on the Judiciary

                             Washington, DC

    The Subcommittee met, pursuant to notice, at 2:22 p.m., in 
Room 2141, Rayburn House Office Building, the Hon. Chip Roy 
[Chair of the Subcommittee] presiding.
    Present: Representatives Roy, Jordan, McClintock, Massie, 
Hageman, Hunt, Grothman, Harris, Onder, Gill, Scanlon, Raskin, 
Cohen, Jayapal, Balint, Kamlager-Dove, and Goldman.
    Mr. Roy. The Subcommittee will come to order.
    Without objection, the Chair is authorized to declare a 
recess at any time.
    We welcome everyone to today's hearing on Legislative 
Reforms To End Lawfare. I will now recognize myself for an 
opening statement.
    Welcome. We are here today to discuss potential legislative 
reforms to end lawfare by State and local prosecutors. Rather 
than debating political opponents on substance, my colleagues 
on the other side of the aisle thought they could win the 2024 
election through the use of partisan lawfare tactics.
    Lawfare has been defined as, quote, ``the strategic use of 
legal proceedings to intimidate or hinder an opponent.'' 
Lawfare violates the fundamental mission of prosecutors. A 
prosecutor's job is to do justice. As a former Assistant United 
States Attorney, I made it my duty to uphold the law with 
fairness on those I charged, making sure their civil liberties 
were kept intact. Additionally, when I was a prosecutor, I 
methodically ensured the cases that were brought before me 
would not fall to political pressure or succumb to outside 
influence, especially to score cheap political points. Every 
American deserves to have a justice system that is divorced 
from the political whims of elected officeholders, political 
parties, and personal vendettas.
    In their political pursuit of President Trump, however, we 
saw State and local prosecutors abuse professional norms in 
favor of achieving indictments against their target. Prior to 
the 2024 election, President Trump was criminally indicted four 
times. Let's take a quick look at the State and local lawsuits 
brought against President Trump.
    First up, Fulton County. Georgia District Attorney Fani 
Willis' 41-count indictment against 19 defendants, which 
included President Trump, his attorneys, his former White House 
Chief of Staff, and a former Justice Department official. The 
politicized nature of this prosecution is hard to ignore. A 
mere four days before the indictment, DA Willis launched a 
campaign-fundraising website highlighting her investigation 
into President Trump. Though DA Willis' investigation was first 
reported in February 2021, it was not until President Trump 
announced his candidacy that she brought charges. Later, DA 
Willis requested that the trial begin on March 4, 2024, the day 
before Super Tuesday and just eight days before the Georgia 
Presidential primary.
    To charge President Trump and his codefendants, DA Willis 
used a broad interpretation of Georgia's RICO law, which is 
intended to be used to prosecute criminal enterprises that 
infiltrate legitimate businesses and use interstate commerce. 
For background, RICO statutes are used to prosecute organized 
crime mob bosses, street gang leaders, and other crime 
syndicate heads, not typically elected officeholders on absurd 
charges.
    Prior to indicting President Trump, she coordinated with 
Special Counsel Jack Smith and the partisan January 6th 
Committee. Her lead prosecutor, Nathan Wade, met with the 
Biden-Harris White House on multiple occasions.
    Then, we have New York Attorney General Letitia James, who 
has made her disdain for President Trump well known. When she 
ran for New York Attorney General, she made many personal 
attacks against President Trump, calling him things like con 
man, carnival barker, and even an illegitimate President. As 
soon as she took office, AG James began investigating President 
Trump. In September 2022, she sued the President, alleging that 
he and his company had committed fraud to inflate the value of 
his properties.
    Now, let's turn to Manhattan District Attorney Alvin Bragg, 
who indicted President Trump with 34 counts of falsifying 
business records which was tied to an unknown Federal crime 
which aggravated the charges to felonies. The Manhattan 
District Attorney's Office had been investigating President 
Trump since 2018, but it wasn't until after President Trump 
announced he was running for President in late 2022 that Bragg 
elected to resurrect the zombie case against President Trump.
    Who did he bring on to help this politicized investigation? 
Bragg hired senior Biden-Harris Justice Department official, 
Michael Colangelo, to jump-start his office's investigation of 
President Trump, reportedly due to Colangelo's, quote, 
``history of taking on Donald J. Trump and his family 
business,'' while working for the New York Attorney General's 
Office.
    One should be equally concerned if it were a Republican 
District Attorney engaging in this conduct toward a former 
Democrat President, Cabinet Secretary, or White House official.
    These prosecutions are precisely what former Attorney 
General Robert Jackson warned us about. Attorney General 
Jackson warned about the most dangerous power of the 
prosecutor, quote,

        That he will pick people that he thinks he should get rather 
        than pick cases that need to be prosecuted. It is here that law 
        enforcement becomes personal, and the real crime becomes that 
        of being unpopular with the predominant or governing group, 
        being attached to the wrong political views, or being 
        personally obnoxious to or in the way of the prosecutor 
        himself.

That is precisely what we have here.
    This is why Congress must address Democrats' lawfare 
efforts by popularly elected State and local prosecutors 
against Federal officials. In fact, many of my Democratic 
colleagues on this Committee are vocal proponents of a fair 
criminal justice system, calling an end to perceived needless 
instances of overzealous prosecution, wrongful arrest, and 
detention and limiting incarceration overall. What better way 
to achieve these goals than engaging in this hearing to uncover 
possible missteps by State and local justice systems and 
ushering legislation to rectify these glaring blind spots.
    Current law does not adequately protect Federal officials 
from rogue State and local attorneys who stack unwarranted 
charges against their political opponents. Under current law, 
the option to remove civil or criminal cases from a State Court 
to a Federal Court is limited to Federal agency officials and 
legislative and judicial officers.
    Our colleague on the Judiciary Committee, Congressman Fry, 
has a bill that would fix this problem. The Promptly Ending 
Political Prosecutions and Executive Retaliation Act of 2025 is 
designed to protect our Nation's leaders from lawfare tactics. 
This bill gives both current and former Presidents of either 
party, Vice Presidents, and Federal officials the ability to 
remove civil and criminal cases against them from a State Court 
to a Federal District Court. The bill also codifies the 
immunity recognized by the U.S. Supreme Court for official acts 
carried out by a Federal official.
    This bill should not be misconstrued as a get-out-of-jail-
free card. Far from it. It should be an opportunity for 
individuals to have a shot of nonpoliticized due process 
experience. Make no mistake. If a Federal official were to 
commit theft, fraud, assault, or other crime, they should be 
held accountable regardless of political party or policy views. 
This bill introduced should be welcome by both parties as no 
individual acting within their duties should be sought after 
because of whom they work for or their political leanings.
    I'm looking forward to discussing that particular bill as 
well as the need for legislative fixes in this space today. I 
want to thank all our witnesses for being here today. We look 
forward to your testimony and the robust conversation on how we 
can move forward and fix this problem.
    I now recognize the Ranking Member, Ms. Scanlon, for her 
opening statement.
    Ms. Scanlon. Thank you.
    I would like to welcome our witnesses here to the 
Subcommittee on the Constitution, but it's a little hard to do 
so when this Committee and apparently the entire House Majority 
seems to have lost their way and forgotten the basic terms of 
that Constitution. Instead of acting as a coequal branch of 
government as designed by our founding document, this House 
Majority is content to abdicate Congress' authority to make and 
fund laws to a would-be dictator and his billionaire tech bro.
    Speaker Johnson and House Republicans have gone along with 
White House efforts to gut basic services that Americans rely 
on, whether at the VA, Social Security Administration, or the 
National Institute of Health, and they've teed up huge cuts to 
Medicaid, SNAP, and more, all so they can give more tax breaks 
to their billionaire buddies that will explode our national 
debt. Instead of lowering costs for American families, they've 
encouraged the President's tariff wars that are already driving 
up inflation and tanking the stock market.
    The bills our House Republican colleagues are filing and 
bringing to the floor are an embarrassment. They're seemingly 
engaged in a contest of who can debase and subjugate themselves 
to the President the most, with measures like adding Trump's 
face to Mount Rushmore, designating his birthday as a national 
holiday, and printing $250 bills with his portrait on them, 
which brings us to the bill that forms the basis for today's 
hearing.
    It's another attempt to refashion the rule of law to 
flatter a narcissist and felon in chief. We know that because 
it was first introduced last term to benefit one man and one 
man only, Donald Trump, as he faced 34 felony convictions in 
New York, a criminal case in Georgia, and hundreds of millions 
of dollars in civil judgments all in State Courts.
    This legislation appears to be an unconstitutional power 
grab by the Federal Government and a direct infringement on 
State sovereignty that would upend the Framers' carefully 
calibrated balance of power between what are supposed to be two 
equal sovereigns.
    In their shameless quest to help Donald Trump and his 
cronies evade justice in our State Courts, Republicans would 
have Congress exceed the scope of its authority and grant 
Federal jurisdiction over a host of State Court cases. For all 
their talk about federalism, it begs the question: Is there any 
fundamental principle that House Republicans are not willing to 
abandon in servitude to this President?
    The bill before us, the so-called Promptly Ending Political 
Prosecutions and Executive Retaliation Act, amends 28 U.S.C. 
1442, the Federal officer removal statute, and other provisions 
related to the removal of cases from State to Federal Court.
    Under Section 1442, a Federal officer can remove a State 
criminal or civil matter to Federal Court if the case relates 
to acts taken, quote, ``under control of the office,'' meaning 
that the Federal officer was acting within the scope of his or 
her official duties. As a statutory and Constitutional matter, 
the party seeking removal bears the burden of showing that a 
case falls within the Federal Court's jurisdiction.
    Under the Supreme Court's decision in Mesa v. California, 
removal is not permissible to absent a colorable Federal 
defense. The Federal officer removal statute is intended to 
prevent Federal officers from being improperly punished for 
carrying out their duties. It's not a license for them to go 
around doing whatever they want with no accountability.
    While I'll leave the point-to-point analysis of this bill 
to our expert witness, Professor Elizabeth Beske, I will 
highlight that this bill is troubling for a few reasons.
    First, it would allow any former Federal official to remove 
State cases for acts taken under color of office. More 
concerningly, the bill would allow a sitting or former 
President or Vice President to remove cases for or relating to 
any act while in office, even ones that involve their personal 
private conduct unrelated to their official duties.
    It seeks to provide immunity for the President, Vice 
President, and political officers under a misguided 
understanding of the Supremacy Clause and effectively flips the 
normal presumption against removal to a presumption in favor of 
it. In other words, this bill goes a long way toward enshrining 
in American statute the idea that we're ruled by a king who's 
above the law.
    Overall, this bill is unjustified, unworkable, and 
misguided, especially for the time we find ourselves in. Rather 
than admit that the legislation they proposed is blatantly 
unconstitutional, our Republican colleagues have tried to 
characterize it as a response to politicized law enforcement 
leveled at Mr. Trump and his allies. In fact, the Chair just 
tried to describe the bill under consideration as an effort to 
ensure that all Americans enjoy a justice system free of 
politicization.
    As is so often the case, Republican accusations are 
frequently confessions. If our Republican colleagues want to 
talk about politicized law enforcement, let's have at it, 
because we don't have to go any further than right here in our 
Nation's capital to find the most egregious examples and in 
just the past six weeks.
    Donald Trump's Department of Justice has fired hundreds of 
career prosecutors and FBI agents for doing their jobs without 
fear or favor. He has targeted those who helped investigate and 
prosecute the people who violently attacked the Capitol on 
January 6th, while also pardoning 1,500 of his MAGA followers 
who rioted and injured hundreds of law enforcement officers 
that day. In doing so, he put his Presidential seal of approval 
on political violence, so long as it supports him. His 
Department of Justice has made corrupt quid pro quo deals, 
dropping Federal corruption charges against Eric Adams in 
exchange for the mayor's agreement to his political agenda.
    In just his first 44 days in office, Donald Trump's made 
his cynical vision of government clear. He's wasted no time 
using the power of the Presidency to silence the people whose 
job it is to hold him and his billionaire buddies accountable 
by firing at least 17 inspectors general, making it harder for 
the truth about fraud and abuse in our government to be 
exposed, and effectively ending investigations into fraud and 
abuse by--you guessed it--Elon Musk and the members of the 
Trump White House.
    He's moved to take control of independent agencies designed 
to hold the powerful accountable, like the FEC, CFPB, and SEC, 
and using the FCC to go after broadcasters that produce content 
that the President doesn't like.
    This President has undermined the power of the people and 
this Congress--something everyone in this room should be 
outraged by refusing to faithfully execute the laws that this 
body has passed and the money that we've appropriated, and is 
attempting to unilaterally dismantle programs and entire 
agencies that Congress created and only Congress can eliminate.
    This is all happening every day out in the open. Condemning 
these blatant abuses of power is not the conversation our 
Republican colleagues want to have. Since the day he took 
office, Donald Trump has trampled on the rule of law that forms 
the very foundation of our democracy, using the power of the 
Presidency to demand vengeance and unquestioned loyalty. He's 
undertaken politically motivated legal actions against his 
perceived enemies. If you want to talk about lawfare, that's 
lawfare right there.
    Our Founders designed a democratic Republic built on the 
rule of law, not the rule of a king. As this administration 
tests that fundamental principle, it's counting on our 
Republican colleagues to be too weak and cowardly to stand up 
to it. Thus far, that's true. We took an oath to preserve and 
protect the Constitution. That's our duty as Members of 
Congress, and that's what my Democratic colleagues and I plan 
to do.
    I yield back.
    Mr. Roy. I now recognize the Chair of the Full Committee, 
Mr. Jordan, for his opening statement.
    Chair Jordan. Thank you, Mr. Chair.
    Lawfare is real. It's as real as it can be.
    On November 15, 2022, President Trump announces he's 
running for office. Three days later, Attorney General Garland 
names Jack Smith as Special Prosecutor. Now, I understand 
that's Federal and we're focused on State and local prosecutors 
here, but it's lawfare nonetheless.
    A few months after President Trump announced he's running 
for office, Alvin Bragg brings a case against President Trump, 
a case that his predecessor said wasn't there, a case that the 
Fed, the Southern District of New York, everyone said wasn't 
there, but Alvin Bragg brings it because President Trump is now 
running for the highest office in the land.
    Then a few months after that, Fani Willis brings her 
ridiculous case against President Trump and other Federal 
officials, all designed to make it so President Trump wouldn't 
win the election.
    Of course, all that was preceded by--all that was preceded 
by the whole Russia collusion baloney--complete baloney--where 
the FBI--think about this--the FBI went to the secret court. 
They took information from the Clinton campaign, that had first 
been sent to the Perkins Coie law firm, that are then being--
that they then hired Fusion GPS, who then hired a foreigner who 
put together a bunch of lies in a dossier, they take it to the 
court, and they use that as a reason to go spy on President 
Trump's campaign.
    So, lawfare is as real as it gets. We have a bill 
introduced by our colleague, Mr. Fry, that seeks to address 
part of this. It says if you're a Federal official and some 
crazy local prosecutor comes after you can move that case to 
Federal Court. Go figure. That makes so much sense. That's all 
this bill does.
    I appreciate the Chair having this hearing. I appreciate 
our good witnesses who are here to talk about what we've 
witnessed in this great country where it's supposed to be equal 
treatment under the law. You're not supposed to use the law to 
target your political opponents. We have a piece of legislation 
that makes good commonsense that we hope to pass tomorrow in 
the Full Committee, but today we're going to hear about it.
    With that--again, I appreciate our witnesses, and I 
appreciate the Chair of this important Committee having this 
hearing. I yield back.
    Mr. Roy. I thank the Chair for his opening statement.
    I now recognize the Ranking Member, Mr. Raskin, for his.
    Mr. Raskin. Thank you, Mr. Chair. Welcome to all our 
witnesses.
    The Majority Republicans call it lawfare when Donald Trump 
is held to the rule of law and given every right of due 
process. We call it lawfare when the Trump Administration 
violates the rule of law and tramples the due process rights of 
Americans, including prosecutors and FBI agents.
    Mr. Chair, we have no kings here, no queens, no titles of 
nobility, no serfs, and no slaves. Our revolution overthrew 
monarchy and the established church. It made our Constitution 
supreme over the monarchical and oligarchical political 
ambitions of any man. The 13th and 14th Amendments abolished 
slavery and gave equal protection to all, royal status to none. 
In our time, Donald Trump's crime spree throughout American 
society has tested the hard one principle that we are all equal 
and that no one is above the law.
    The Supreme Court that Trump has repeatedly bragged about 
packing and stacking to destroy Roe v. Wade not only brought 
the curtain down on the freedom and health security of tens of 
millions of American women trapped in GOP-controlled, 
antichoice States; it also made the President absolutely immune 
from prosecution for crimes he commits under the so-called core 
functions of his office, presumptively immune from prosecution 
for other so-called official acts, and subject to prosecution 
only for private unofficial acts.
    After more than two centuries, this bracing new taxonomy 
for licensing Presidential criminality was announced by the 
Roberts Court in a 6-3 decision in U.S. v. Trump. It creates 
Presidential exceptionalism, a plainly dangerous doctrine which 
overturned a unanimous ruling of the D.C. Circuit Court of 
Appeals.
    Even that shocking burst of finger-painting on the 
Constitution isn't enough for Trump and his crowd who seek now 
complete immunity and impunity from the laws that bind the rest 
of us. It's not even enough for them to appoint a nationwide 
crew of embarrassingly servile judges like Aileen Cannon, who 
may as well be on the bench in Putin's Russia, as she shows 
little fidelity to the rule of law but fastidious devotion to 
the whims of her dear leader.
    Now, they want to pass something called the PEPPER Act to 
let Trump and his accomplices get their political corruption 
and election-fixing cases removed from any State Court in the 
land and put in front of far more submissive and pliant Trump 
appointees in Federal Court.
    Donald Trump tried this move in one of his criminal cases, 
the one in New York City where he was found guilty of 34 felony 
criminal counts of falsifying business records to cover up 
hush-money payments he had paid to a mistress before the 2016 
election. There, his judge rejected his request to move 
everything to Federal Court, saying Trump had failed to meet 
both the current statutory and Constitutional requirements for 
doing that.
    As Judge Hellerstein observed in his ruling, the evidence 
overwhelmingly suggests that the matter was a purely personal 
item of the President, a coverup of an embarrassing event. Hush 
money paid to an adult film star is not related to a 
President's official acts. It does not reflect in any way the 
color of the President's official duties. Removal to Federal 
Court is reserved for cases where there is an actual Federal 
defense.
    Let's say the President was tried in Florida State Court 
for assaulting a citizen but his defense was that the alleged 
victim was a soldier, and he was just administering fair 
punishment as Commander in Chief of the Army in a time of 
actual conflict. In that hypothetical case, it would be removed 
so the Federal judiciary could handle the Federal question 
defense. There was plainly no Federal question defense in 
Trump's hush-money record falsification scheme.
    Now, scrambling to appease Trump, an incorrigible, 
recidivist lawbreaker who is looking for a way to disappear all 
of his State Court civil and criminal prosecutions, our 
colleagues propose to amend the law so that a President or Vice 
President or even a former President or Vice President can 
remove a State civil or criminal prosecution to Federal Court 
whenever that case is brought, quote,

         . . . for or relating to any act while in office, even if that 
        act is of a completely private and personal nature, or where 
        the State Court's consideration of the claim or a charge may 
        interfere with, hinder, burden, or delay the execution of the 
        duties of the President or Vice President.

    This broad, gaping language would in practice mean that no 
State Court in America could ever conduct a criminal trial of 
Donald Trump or any other President again even if the alleged 
conduct--say, hypothetically, sexual abuse or criminal fraud--
has no relationship to any of his official Presidential acts. 
After all, any litigation can obviously hinder or burden the 
execution of official duty.
    It would also permit Trump and his associates to remove the 
State Court criminal cases now pending in Georgia related to 
the Trump conspiracy to overthrow the 2020 Presidential 
election.
    This bill is designed to trash basic jurisprudential 
principles, including federalism, that have served us well 
since the 18th century. The conceit behind it is the pathetic 
claim that Donald Trump is just profoundly misunderstood and a 
victim of the judicial process and a target of unfair 
prosecutions, although no court has ever once found that.
    Yes, that Donald Trump. He's the victim, according to our 
colleagues. The billionaire businessman who's been involved 
in--check this out--more than 4,000 lawsuits, some in which he 
is sued as a defendant by, for example, frustrated students at 
Trump University or ex-mistresses or golf clubs alleging 
nonpayment or plumbers, painters, electricians, and small 
business contractors alleging failure to pay on their 
contracts. Most of the ones I could find were ones in which he 
is the plaintiff, deploying his army of lawyers to sue 
thousands of people and businesses, including casino patrons, 
real estate partners, business tenants, and media entities. 
Most recently, he sued ABC and then CBS for $20 billion.
    To hear our friends tell it, Donald Trump is just an Eagle 
Scout who respects women, would never cook the books, and keeps 
his hands to himself. The Donald Trump I know about is a 
civilly adjudicated sexual abuser in New York, a convicted 
criminal felon, and the only twice-impeached President in 
American history, who was most recently impeached in this House 
for inciting an insurrection against the Constitution, the 
Congress, and his own Vice President. The Senate voted 57-43 to 
convict him, meaning that although Trump narrowly beat the 
Constitutional spread, robust bipartisan majorities voted that 
he had indeed incited insurrection against our government.
    Now, look, if you want to see real lawfare, if that's 
something really in your scopes, then open your eyes to the 
U.S. Attorney's office here in the District of Columbia. The 
pro-January 6th insurrectionist turned U.S. Attorney for D.C., 
Ed Martin, has fired more than a dozen career prosecutors 
focused on violent crime from his office simply for doing their 
jobs and doing their jobs well. He fired them because they had 
worked on the January 6th cases which they were assigned to do, 
prosecuting Proud Boys, Oath Keepers, and other extremists who 
violently assaulted our police officers, and they were sacked.
    Just last week, Mr. Martin demoted several other top 
prosecutors and career supervisors to entry-level positions, 
again, as retribution for having simply done their jobs in 
overseeing January 6th prosecutions. That is lawfare. That is a 
violation of the due process rights as well as the civil 
service rights of American citizens who did nothing other than 
obey the law and do their jobs.
    This is just the tip of the iceberg when it comes to the 
administration's attacks on the rule of law in its first month, 
from the corrupt quid pro quo in New York City with Mayor 
Adams, which led to the resignation of multiple Department of 
Justice lawyers, including the U.S. Attorney for the Southern 
District who had been a Justice Scalia clerk and a career-long 
member of the Federalist Society, and she said she couldn't put 
up with that and she decided to quit; her assistant, another 
conservative lawyer who had clerked on the Supreme Court for 
Chief Justice Roberts, and he said you would have to be a fool 
or a coward to go along with that corrupt bargain between 
Donald Trump and Mayor Adams.
    They have halted anticorruption task forces. They've 
suspended enforcement of the Foreign Corrupt Practices Act. 
They have suspended antikleptocracy and anticorruption 
initiatives, and on and on.
    If you want to look at lawfare, let's look at what's going 
on right in front of our eyes today, Mr. Chair. That's what we 
should be doing instead of going after some imaginary lawfare 
by State and local prosecutors who did nothing other than their 
jobs, enforcing the law in their States, and not a single judge 
or appeals court or even the Supreme Court under Roberts 
Court's spell has said anything about those people doing 
anything remotely unethical.
    I yield back to you.
    Mr. Roy. Without objection, all other opening statements 
will be included in the record.
    We will now introduce today's witnesses.
    First, Mr. George Terwilliger. Mr. Terwilliger is an 
attorney with more than four decades of experience in both 
private practice and government service. Before entering 
private practice, he served for 15 years in the Department of 
Justice as a prosecutor, United States Attorney for the 
District of Vermont, Deputy Attorney General, and Acting 
Attorney General. In private practice, Mr. Terwilliger has 
represented a multitude of private companies, Members of the 
House and the Senate, Cabinet officers, and other Executive 
Branch officials.
    Mr. Daniel Epstein. Mr. Epstein is the Vice President at 
the America First Legal Foundation, a nonprofit public interest 
law firm. He is also an Assistant Professor of Law at St. 
Thomas University School of Law, where his research includes 
Constitutional law, American legal history, Federal Courts and 
jurisprudence, and civil procedure.
    Ms. Elizabeth Price Foley. Ms. Foley is of counsel at 
Baker-Hostetler, where she practices Constitutional Appellate 
Law. She also serves as a Professor of Law at the Florida 
International University College of Law where she teaches 
Constitutional law, separation of powers, and civil procedure.
    Professor Elizabeth Beske. Ms. Beske is a Professor of Law 
and Associate Dean for scholarship at the American University 
Washington College of Law. Her research focuses on civil 
procedure, Constitutional law, Federal Courts, and legal 
writing.
    We thank our witnesses for appearing today, and we'll begin 
by swearing you in. Would you please rise and raise your right 
hand?
    Do you swear or affirm under penalty of perjury that the 
testimony you're about to give is true and correct to the best 
of your knowledge, information, and belief, so help you God?
    Let the record reflect that the witnesses have answered in 
the affirmative.
    Thank you, and please be seated.
    Please know that your written testimony will be entered 
into the record in its entirety. Accordingly, we ask that you 
summarize your testimony in five minutes. I remind each of you 
to turn the microphone on before you begin speaking.
    Mr. Terwilliger, you may begin.

               STATEMENT OF GEORGE J. TERWILLIGER

    Mr. Terwilliger. Thank you, Mr. Chair, Ranking Member, and 
the Members of the Committee, for inviting me to appear here 
today to discuss lawfare by State authorities.
    I have three suggestions for your consideration to curb 
State lawfare targeting Federal officials and to restore the 
Federal officer removal statute to be as Congress has intended 
it over many years.
    First, amend the removal law to expressly cover former 
Federal officials.
    Second, support the Supremacy Clause with legislation 
providing an expanded scope of removal to include Federal Court 
jurisdiction where there are questions of Federal law in 
removal cases.
    Third, codify Supremacy Clause immunity of Federal 
officials.
    A Constitutional line is crossed when State officials use 
State law to control Federal activity. In 1819, Chief Justice 
Marshall laid down the law in McCulloch v. Maryland, ruling 
that under the Supremacy Clause, quote,

        The States have no power to impede, burden, or in any manner 
        control the operations of the general government.

    Congress, over the decades, in a succession of amendments 
of the Federal officer removal statute, expanded the protection 
of Federal officers from State prosecutions. As recently as 
2011, Congress expanded removal to cover conduct merely, quote, 
``related to,'' a Federal official's functions, but courts have 
pushed back, ruling contrary to that Congressional intent.
    In a 2023 decision, the 11th Circuit Court of Appeals 
overruled 200 years of practice by taking removal possibility 
away from all former Federal officials and again raising the 
bar for removal contrary to Congress' 2011 amendment that 
lowered it. Two members of that appeal panel urged Congress to 
amend, recognizing what they called a, quote, ``nightmare 
scenario,'' where allowing, quote,

        A rogue State's weaponization of the prosecution power could go 
        unchecked and fester, which could paralyze our Republic-
        democratic system of government which depends on having 
        talented and enthusiastic people willing to serve.

    Congress should amend 1442(a) to expressly cover former 
officials, but it needs to do more than that to curb the 
burgeoning lawfare by States using legal actions to attack the 
discretionary exercise of Executive authority.
    Georgia DA Fani Willis' prosecution of my client, Mark 
Meadows, is a great example of that lawfare. Congress, in 1939, 
passed a statute which authorized Presidential Assistant 
positions and established that their duties, by law, quote, 
``shall be as prescribed by the President.'' Willis, 
nonetheless, claims that the Fulton County District Attorney 
can decide what Presidential Assistants can and cannot do. Her 
State prosecution charged the White House Chief of Staff for 
setting up and participating with the President in a telephone 
call to a Georgia official.
    The case against Mr. Meadows should have been removed and 
summarily dismissed under the Supremacy Clause, but the Federal 
Courts in Georgia, in contravention to Congressional intent, 
misapplied the removal statute, not only ruling out former 
officials, but raising the bar by adding the absurd requirement 
that to get a State prosecution removed to Federal Court a 
Federal official has to prove that he was authorized to commit 
the very crime the State alleges in his Federal role.
    Now, a Federal Court in Arizona has followed the 11th 
Circuit's lead, blocking the path to Federal immunity and 
allowing the Arizona Attorney General to prosecute conduct in 
the very West Wing of the White House, the beating heart of the 
Executive Branch.
    Congress needs to act, reaffirming its intent to ensure 
that State claims against Federal officials doing their jobs 
get moved to Federal Courts and those that are barred by the 
Supremacy Clause are summarily dismissed.
    Chief Justice Marshall had it right 200 years ago when he 
drew that bright line for closing State control of Federal 
activities. The draft legislation here presents commonsense 
steps for Congress to address lawfare where State authority 
oversteps Constitutional bounds. It may be that even more needs 
to be done, but this bill would be a solid start.
    Thank you, Mr. Chair.
    [The prepared statement of Mr. Terwilliger follows:]
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    Mr. Roy. Thank you, Mr. Terwilliger.
    Mr. Epstein, you may begin.

                 STATEMENT OF DANIEL Z. EPSTEIN

    Mr. Epstein. Chair Roy, Ranking Member Scanlon, and the 
Members of the Subcommittee on the Constitution and Limited 
Government, thank you for inviting me to testify on this 
important matter.
    President Trump overcame the most vindictive weaponization 
of the justice system against an American leader in our 
Nation's history. Partisan operatives sought to destroy 
President Trump in 2016, when the Clinton campaign branded him 
as a Russian asset by laundering campaign opposition research 
to the FBI to spy on the Trump campaign, leading to multiple 
investigations by Special Counsel Mueller. The Mueller 
investigation substantiated no criminal activity by President 
Trump, nor could it. Its jurisdictional authority was based on 
a lie manufactured by Christopher Steele.
    As the American people would witness, the first special 
counsel investigation was mere child's play. Two impeachment 
attempts, four criminal indictments, one $400 million civil 
judgment, one mugshot, three States attempting to disqualify 
him from their ballots, two Democratic-nominated Presidential 
opponents, and two assassination attempts later, Democrats 
would finally claim their scalp when they obtained a conviction 
against President Trump in a New York State Court, weeks before 
the American people overwhelmingly reelected him with a 
historic landslide mandate.
    The American people saw through the coordinated hit job on 
their President that culminated in a conviction by a radically 
liberal jury pool in front of a judge who donated to Trump's 
first 2024 election opponent, President Joe Biden, and whose 
daughter works for a firm that represented both Joe Biden and 
Kamala Harris' Presidential campaigns--campaigns against 
President Trump, a party arguing before her father.
    Despite these clear questions about Acting Justice Juan 
Merchan's ability to appear impartial, the jury unanimously 
convicted President Trump of concealing a crime that it did not 
even need to agree on or share publicly. While the New York 
jury, despite obvious legal errors and corrupt motivations, did 
convict President Trump, the voters overwhelmingly acquitted 
him on election day, making it clear that they understood the 
fix was in.
    The State of New York lacked jurisdiction over the campaign 
charges against President Trump. The State of New York did not 
have jurisdiction to hear a case centered on Federal election 
law. The District Attorney Alvin Bragg violated the Supreme 
Court doctrine known as the primary jurisdiction doctrine, 
which says that a court should stay or dismiss a claim when it 
implicates issues within the special confidence of a Federal 
administrative agency. Here, that agency was the Federal 
Election Commission.
    The New York case against President Trump alleged violation 
of the Federal Election Campaign Act of 1971. The FECA 
violates--vests exclusive jurisdiction over issues of Federal 
elections and the FEC and the Department of Justice. In 
President Trump's case, the FEC did look at the allegations and 
then decided they were not worth further investigation. This 
should have been the end of the matter, but Biden's DOJ did not 
enforce its exclusive jurisdiction, allowing a politically 
motivated district attorney to bring his own case built on the 
alleged violation of FECA.
    Second, a top official in Biden's Justice Department was 
dispatched to assist the Manhattan District Attorney's Office's 
prosecution of President Trump. In coordination with President 
Biden and his campaign's lawfare strategy, the New York 
District Attorney Alvin Bragg resurrected a hush-money zombie 
case under a legal theory that Bragg's predecessor had 
previously sent back into the grave out of concerns that felony 
charges would not hold up in court.
    Bragg's commitment to getting Trump gained him the support 
of senior Biden political operatives. One day after Bragg 
announced his primary campaign against his predecessor, Bragg 
received a contribution from Chiraag Bains, who would later 
become Deputy Assistant to the President in the Biden White 
House.
    Biden's operatives for Bragg did not stop there. In 
December 2022, New York District Attorney Alvin Bragg 
reportedly hired Mike Matthew Colangelo to jump-start his 
office's investigation of President Trump due to Colangelo's 
history of taking on Donald Trump and his family's businesses. 
At the Biden Department of Justice, Colangelo served as a 
politically appointed Acting Associate Attorney General, the 
third highest-ranking official in the Department of Justice.
    The Committee's thorough investigation revealed that 
Bragg's--this Committee's thorough investigation revealed that 
Bragg's hush-money prosecution was coordinated with Biden. 
Despite the obvious links between Biden's Department of Justice 
and Bragg's District Attorney Office, Attorney General Merrick 
Garland refused during a Congressional hearing to commit to 
turning over communications between his Department of Justice 
and Bragg's office, and the Department of Justice's followup 
response to the Committee denied the existence of such 
communications.
    Our work at America First Legal revealed that, in fact, 36 
responsive records existed between the Department of Justice 
and the New York District Attorney's Office.
    Thank you.
    [The prepared statement of Mr. Epstein follows:]
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    Mr. Roy. Thank you, Mr. Epstein.
    Professor Foley, you may begin.

               STATEMENT OF ELIZABETH PRICE FOLEY

    Ms. Foley. Chair Roy, Ranking Member Scanlon, and the 
Members of the Subcommittee, first, good afternoon, and thank 
you for the opportunity to testify.
    Lawfare is something we should all agree is bad. The 
definition of lawfare is using the legal system either through 
criminal or civil suits to go after your political opponents. 
Firing people in the Executive Branch doesn't fit that 
definition. So, it's not lawfare.
    Lawfare is something that has torn this country apart. It's 
deepened our political divide, it's undermined the rule of law, 
and it's distorted, if not destroyed, America's trust in 
government, particularly its courts. So, the good news, 
however, is that Congress can do something about it.
    I want to talk about the removal amendment, the bill that 
was just dropped, which I had a draft of a little bit earlier. 
I will focus on that, but on the drive over I thought to 
myself, what really Congress ought to do--if I had my wish 
list--is I would ask you to consider reorganizing the Federal 
Courts.
    You have plenary control over lower Federal Courts under 
Article III, Section 1. You could take DDC, the District Court 
in D.C., and the D.C. Circuit, and you could fold it into a new 
13th Circuit. You could wrap it into a circuit with West 
Virginia, Tennessee, and Arkansas, and you could help dilute a 
lot of the bias that's happening today that's fueling a lot of 
this lawfare. It's not going to solve all problems, but, 
frankly, I think that's a very deep problem that we have with 
the D.C. Circuit and the DDC that you need to think about 
finding creative ways to solve. So, that's one point.
    With regard to removal, you can also discourage lawfare by 
toying with or amending the Federal officer removal statute. 
That's going to be really important, because if you make 
removal more readily available, you discourage lawfare because 
you allow these cases to be taken into the Federal Court where 
you have lifetime-tenured judges who will represent the 
interest of the Federal sovereign and they're more insulated 
from the political whims than their State counterparts are. 
These Federal judges will then be responsible for deciding the 
legal scope of important Federal defenses such as immunity.
    Removal to Federal Court also allows a Federal jury to 
decide the merits of the charges levied by the State against 
the Federal official, and that's really important because 
Federal jury pools are often geographically larger, and this is 
going to help reduce or dilute the bias that a State or a 
locality may have against the Federal Government, particularly 
if that hostility toward the Federal Government is sort of 
focused in one particular locality, such as Fulton County, 
Georgia, or Manhattan.
    Now, if we don't have liberal removal standards, if the 
current removal statutes are not being liberally construed as 
the Supreme Court says they should be, then we have a problem--
as the Supreme Court identified in Tennessee v. Davis--of 
having rogue States that are hostile to actions by the Federal 
Government, and those rogue States then undermine Federal 
authority through lawfare waged against Federal officials.
    The lawfare that has occurred in Georgia and New York have 
revealed at least three substantive amendments to the removal 
statute that I think are important. First, George has already 
talked about the need to have the removal statute clearly State 
that it applies to former Federal officials, such as Mark 
Meadows.
    It is remarkable that the 11th Circuit which denied removal 
of Mr. Meadows' case did so because he was a former official, 
but two of the three judges on the panel is Judge Rosenbaum and 
Judge Abudu; the first one is an Obama appointee and the second 
one is a Biden appointee. Two of the three judges on the panel 
implored you, implored Congress, to amend 1442 to include 
former officials. That says everything you need to know that 
this is not political. This is for the good of the country.
    They even said--they went so far as to say that, if you 
don't do this, it could destroy the entire system of 
government. They said it is a risk that, quote, ``keeps them up 
at night.'' OK? Those are not light words by Democratic 
appointees. So, at a minimum, I think you need to amend 1442 
for that.
    The other thing I think you need to do is make clear that 
removal is allowed for the President and the Vice President. 
George already touched on that issue.
    I'll stop there and look forward to your questions. Thank 
you.
    [The prepared statement of Ms. Foley follows:]
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    Mr. Roy. Thank you, Professor Foley.
    Professor Beske, your time may begin.

               STATEMENT OF ELIZABETH EARLE BESKE

    Ms. Beske. Thank you.
    Chair Jordan, Ranking Member Raskin, Chair Roy, Ranking 
Member Scanlon, and the Members of the Subcommittee, it is a 
great honor and a privilege to be part of your deliberative 
process, and I thank you for the invitation.
    My name is Elizabeth Earle Beske, and I'm a Professor of 
Law at American University Washington College of Law where I 
teach Federal Courts, Constitutional law, and civil procedure. 
I went to Princeton University and Columbia Law School, and 
after law school, I clerked for Patricia Wald and Justice 
Sandra Day O'Connor, and then I spent some time working as a 
litigator at Munger, Tolles & Olson. As will be apparent, I 
come to you today not as a politician but as a nerdy law 
professor.
    My message today is a simple one. You can add the proposed 
language to the statute, but it may not have the immediate 
broad and sweeping effect you intend. In fact, in many 
instances, it may not do very much.
    Congress, as my colleague just noted, has extensive power 
to confer jurisdiction on the lower Federal Courts. Indeed, the 
Framers conferred on Congress the authority to decide whether 
lower Federal Courts exist in the first place. This vast power 
was limited, however, by Article III of the Constitution.
    The Supreme Court has made clear that Congress may not 
expand the jurisdiction of the lower Federal Courts beyond the 
bounds established by the Constitution. In this area, the 
Constitution requires that all cases have a Federal ingredient.
    Section 1442, which you're seeking to amend, allows the 
removal by Federal officers of civil and criminal actions 
brought against them in State Court for actions they take under 
color of their office, a unanimous Supreme Court held in Mesa 
v. California--written by my boss--that the Constitution only 
permits these kinds of removal where Federal officers assert a 
colorable Federal defense. That is the only time there is the 
requisite Federal ingredient. Any other reading, the court made 
clear, would raise grave Constitutional questions. Even though 
the statute does not include this limitation on its face, we 
must read it in line with the colorable Federal defense 
requirement.
    The Mesa court confirmed that Section 1442 is a pure 
jurisdictional statute, nothing more. In other words, it 
provides a pathway to Federal Courts for a defendant, but does 
not establish a defendant's entitlement to get there. That has 
to come from somewhere else.
    This bill clarifies, as Judge Hellerstein of the Southern 
District of New York had already concluded, that the statute 
covers the President and Vice President. This bill also takes 
up 11th Circuit Judge Rosenbaum's call in Georgia v. Meadows to 
expand coverage to include former Federal officers. The 11th 
Circuit had other things to say on the point of Mr. Meadows' 
effort to remove.
    Of course, current and former Federal officers cannot 
remove simply because they hold a particular Federal office or 
because the suit charges conduct under color of that office. 
The Supreme Court's unanimous opinion in Mesa considered and 
specifically rejected that argument.
    Perhaps anticipating Mesa's clear instruction, the bill 
proposes to create a new immunity provision, 1456. This 
provision confers on all officers a rebuttable immunity under 
Article VI, Section 2, of the Constitution, from any charges or 
claims made under authority of State law.
    The Article VI, Section 2, is the Supremacy Clause. The 
Supremacy Clause does three things. It declares that Federal 
law is the law of the land even in the States, it establishes 
Federal law is supreme, and it states that if ever there is a 
conflict between State law and Federal law, Federal law wins. 
It's basically a choice of law provision.
    In 2015, in another unanimous Supreme Court decision 
written by Justice Scalia, the Supreme Court made clear that 
the Supremacy Clause does nothing else. Stating it plainly, 
Justice Scalia wrote, ``The Supremacy Clause is not the source 
of any Federal rights.'' In other words, it lacks independent 
content.
    A unanimous Supreme Court has clearly told us we cannot 
look at the Supremacy Clause to find Federal rights. It just 
tells us what to do when we find them. Plainly, Section 1456 
and the Supremacy Clause themselves cannot provide content for 
a brand-new and very expansive defense. Section 1456 by itself 
does not solve a Mesa problem.
    The proposed new official immunity provision certainly does 
not enact what some have called the Supremacy Clause immunity 
defense. That term, coined by lower Federal Courts, has no 
relation to the Supremacy Clause it confers immunity where 
officers can demonstrate their actions were necessary to 
fulfill Federal duties--nor does it enact quietly any immunity 
recognized in Trump v. United States.
    Thank you for your time.
    [The prepared statement of Ms. Beske follows:]
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    Mr. Roy. Well, thank you, Professor Beske.
    Ms. Beske. Thank you, sir.
    Mr. Roy. My apologies. We will now proceed under the five-
minute rule with questions.
    The Chair recognizes the gentleman from California for five 
minutes.
    Mr. McClintock. Thank you, Mr. Chair.
    This is the simple, awful truth of the Biden 
Administration. For the first time in American history, a 
Presidential administration targeted its chief rival for 
criminal prosecution, concocted the flimsiest criminal charges, 
turned the Federal law enforcement machinery against it, 
colluded with the Democratic State law enforcement officials to 
do the same. This is the historical record. This happened. When 
we speak of the threats of democracy, what greater threat can 
there be than one party trying to jail its political 
opposition?
    Now, I would, frankly, advise the Ranking Member to be very 
careful in citing the conviction of the President in the 
kangaroo court of Judge Merchan. A staggering range of legal 
experts, from Alan Dershowitz on one side to Jonathan Turley on 
the other, have commented at great length on just how 
outrageous these proceedings were and how likely they are to be 
overturned on competent review. If these professors turn out to 
be correct, the Ranking Member and his many acolytes here in 
this Congress are going to have their words quoted back to them 
for the rest of their lives.
    Now, those who've tried to put their political opponents in 
jail have never fared well before history and nor have their 
apologists. Omar Khayyam put it this way. He said,

        The moving finger writes; and, having writ, moves on: Nor all 
        thy piety nor wit can call it back to cancel half a line, nor 
        all thy tears wash out a word of it.

My Democratic colleagues might want to take a step back and 
consider how history will judge them in the years ahead when 
passions have cooled and the facts remain.
    Now, Mr. Terwilliger, in the events leading up to the Civil 
War, the Confederate States asserted a power of nullification 
and supremacy over the Federal Government that ultimately was 
resolved at Appomattox Court House. I am unaware of any 
assertion by the Confederate States that they could, say, seize 
Abraham Lincoln and try him in their State Courts.
    Is there any precedent in the entire history of our country 
of what the Biden Administration and its partisans in New York 
and Atlanta attempted to do?
    Mr. Terwilliger. Not that I'm aware of, Mr. McClintock. In 
fact, privately and to others perhaps in the President's 
circle, I described the command that Mr. Trump be in Judge 
Merchan's courtroom when he was already a declared candidate 
ready to campaign, that he was truly America's first political 
prisoner. That case needs
to be able to be removed from Federal Court--to Federal Court,
rather.
    Suppose some State authority had decided that Joe Biden was 
not of sound mind and was a danger to himself or others, 
including the country, and decided to civilly commit him under 
State law. Do we think that case ought to have stayed in State 
Court? Of course not. This is a very important step.
    If I may just take the opportunity because I think this is 
so important. Professor Beske is exactly right about the Mesa 
decision which her justice, Justice O'Connor, wrote, and it's 
why I think that when the Committee marks this bill up, you 
ought to just simply incorporate Federal question jurisdiction 
into the basis for removal, because all these removal cases 
involve Federal questions such as what is the scope of the 
duties of the Federal officer. We don't want those decided by 
State Courts.
    Mr. McClintock. Professor Foley, you mentioned how 
dangerous this precedent is to both political parties. What's 
to stop a partisan Republican prosecutor from going after the 
next Democratic Presidential nominee?
    The Democrats keep telling us that any day now, President 
Trump will try to do the same thing to them, even though he had 
four years to do that in his first term and didn't and hasn't, 
of course, in the second so far. If we simply follow the 
precedent that the Democrats have already set, he certainly 
could do that. What other measures do we need to take to 
prevent this from ever happening again?
    Mr. Terwilliger said that President Trump was the first 
political prisoner. We better make damn sure he's the last.
    What can you guide us on?
    Ms. Foley. Couldn't agree more. This is bad for the 
country.
    Yes. Based on this precedent, any Republican State Attorney 
General or now President Trump could appoint a Special Counsel 
and go after Biden and anybody in Biden's Administration. The 
precedent has been set, and it's a bad precedent.
    What's stopping that from happening? Honestly, we were 
talking about it in the conference room beforehand. It's 
because Republicans actually believe in the rule of law. We 
actually believe in norms and preserving them.
    Mr. McClintock. By the way, Liberals used to believe that 
too. Liberals still do, but the Left does not.
    Ms. Foley. They did. When I worked on the Hill from 1987-
1992, I worked for a Democratic Member of Congress who is now a 
U.S. Senator, Senator Ron Wyden. Back then, when Ron Wyden was 
in the House, he was actually kind of moderate and reasonable 
and liberal but not progressive, and he had classical liberal 
values that he adhered to. I think that's been completely lost 
by the Democratic Party. It's why I am no longer a Democrat and 
why so many others are no longer Democrats, including, for 
example, Elon Musk. I know that name makes people go crazy.
    Mr. Roy. Ms. Foley, we've gone over the time.
    With that, I will thank the gentleman from California.
    Ms. Foley. Thank you.
    Mr. Roy. I'll recognize the gentleman from Maryland and the 
Ranking Member, Mr. Raskin.
    Mr. Raskin. Thank you, Mr. Chair.
    First point. The Republicans demanded a Special Counsel in 
the Biden case, and the Republicans demanded a special counsel 
to look into Trump, because they said that the Attorney General 
couldn't be trusted. The Special Counsel was a demand on the 
Republican side.
    In any event, just to get back to the heart of this matter 
in terms of the law, Professor Beske, you point out that the 
Supreme Court rendered this unanimous decision in Mesa v. 
California, establishing that there needs to be a Federal 
question defense to remove from State Court to Federal Court. 
The burden of your testimony is to say that, even if this bill 
were passed that our colleagues are proposing, it wouldn't 
alter that in any way because you can't overturn a 
Constitutional ruling with a mere statute.
    Would there, in fact, be this intended effect of being--of 
allowing Donald Trump and all his associates to be removed from 
State Court prosecutions even if there's no Federal--
independent Federal question defense?
    Ms. Beske. No. It's really important to flag that Mesa 
considered and specifically rejected the United States' 
argument in that case that Federal officers can remove simply 
because they hold a Federal office or simply because the suit 
charges conduct under color of that office. That was 
specifically the United States' argument, and Justice O'Connor 
specifically rejected it.
    Mr. Raskin. That would be like creating a title of 
nobility. If you hold a Federal office, whether it's elective 
or appointed, you can never be charged under State law for 
murder, rape, armed robbery, theft, fraud, and whatever it 
might be. It's just amazing to me that our colleagues would 
make such an argument that's so breathtakingly anti-federalism 
that the States are just drained of all sovereignty over the 
common law crimes that would take place within their State.
    If you're right--and I believe that Mr. Terwilliger just 
conceded that you were--I wonder what you think about his 
suggestion as a way to repair their bill to simply say that 
there must be Federal question jurisdiction. That just is 
tautological. That just restates what the Supreme Court's 
already found, right?
    Ms. Beske. Well, I think what he's saying is it's enough 
that the statute says he's operating under color of his office 
and that this should satisfy Mesa.
    Mr. Raskin. That runs into the Supremacy Clause fallacy 
that you pointed out originally.
    Ms. Beske. Right. That's the argument that Mesa rejected. 
Mesa said that's not enough. That does not satisfy the 
requisite Federal ingredient necessary under Article III, 
necessary to satisfy the Constitution. That argument is a 
nonstarter. They have rejected that unanimously.
    Mr. Raskin. What this really adds up to is some people 
complaining about the fact that Georgia law enforcement 
authorities and New York law enforcement authorities, operating 
independently as States within the sovereignty they've got, 
without any actual evidence that Joe Biden or Joe Biden's 
Department of Justice had anything to do with it, decided to 
prosecute people for crimes committed under their laws.
    They don't like the fact that they weren't able to remove 
to Federal Court where they felt that they had a more receptive 
audience because Donald Trump had appointed a lot of the 
judges, right? So, what is there actually to do? The Supreme 
Court has rendered its decision in the matter, right?
    Ms. Beske. It has. One thing I always teach my civil 
procedure students is, when someone attempts to remove, it's as 
if you pull a lever. It automatically goes to the Federal 
Court, and it's the Federal Court that makes the call as to 
whether removal is or is not a good thing.
    So, Hellerson is a Federal judge. It is Hellerson that made 
the call as to whether the requisites of the Federal removal 
statute were satisfied.
    Mr. Raskin. In the Mark Meadows case, you're saying?
    Ms. Beske. No.
    Mr. Raskin. In the Mesa case.
    Ms. Beske. Hellerson is in the Southern District of New 
York.
    Voice. Hellerstein.
    Ms. Beske. Hellerstein, I'm sorry. He is the person that 
made the call as to whether it was under color of the office 
and whether there was a color of--
    Mr. Raskin. You're saying it was a Federal Court ruling on 
the question of removability.
    Ms. Beske. Correct.
    Mr. Raskin. That would be the same also in Meadows' case.
    Ms. Beske. Correct.
    Mr. Raskin. In the Mesa case. All of them go to Federal 
Court. What you have is Federal judges saying, with the Supreme 
Court backing them up, this doesn't belong in Federal Court.
    Ms. Beske. Correct.
    Mr. Raskin. This is a run-of-the-mill State criminal law 
prosecution.
    Ms. Beske. Correct. It's not under the color of the office, 
and there's no colorable Federal defenses.
    Mr. Raskin. Our colleagues want to turn a Federal case--
turn it into a Federal case because Donald Trump doesn't like 
it.
    With that, I'll yield back to you, Mr. Chair.
    Mr. Roy. Now, I'll recognize the gentlelady from Wyoming 
for five minutes.
    Ms. Hageman. Thank you.
    Ms. Foley, can you describe for us what lawfare is.
    Ms. Foley. Lawfare is the use of legal processes, either 
civil or criminal, to go after a political opponent.
    Ms. Hageman. Mr. Epstein, Alvin Bragg's 34-count indictment 
against President Trump was the first time a former President 
had been indicted in history. Is that correct?
    Mr. Epstein. That is correct.
    Ms. Hageman. The facts of that case had been known for 
years. Isn't that also true?
    Mr. Epstein. Yes, and litigated.
    Ms. Hageman. Why did Federal prosecutors then choose not to 
charge President Trump?
    Mr. Epstein. Obviously, they didn't think that the evidence 
substantiated any crimes.
    Ms. Hageman. Do we yet know what the underlying crime was 
that Donald Trump allegedly committed that was the basis for 
the convictions?
    Mr. Epstein. Well, obviously, the underlying New York 
criminal statute was interpreted broadly, but the supposition 
is that the President, through this alleged hush money scheme, 
was engaging in election crimes, and even, of course, the case 
directly referred to Federal election crimes.
    Ms. Hageman. What do you mean by supposition? Didn't they 
have to prove that's what he had done?
    Mr. Epstein. Right. Of course, there was no unanimous jury 
determination on that. In fact, there was, of course, no proof. 
The argument was there must have been some conspiracy with the 
Trump Organization and others.
    Ms. Hageman. They didn't prove the underlying crime. They 
just convicted him of something in State law. Is that correct?
    Mr. Epstein. Yes. I would also note that based off an 
executive action in New York, there was a stay of these types 
of indictments during COVID. There was, of course, a very 
aggressive reinterpretation of a stay designed to protect 
criminal defendants to go after the President.
    Ms. Hageman. Have you ever seen anything like that New York 
case in your entire years of practice?
    Mr. Epstein. No, never.
    Ms. Hageman. Were you shocked at what happened in that 
court?
    Mr. Epstein. I was, as were many in the legal academy and 
many practitioners.
    Ms. Hageman. I sit here and I listen to all of that, the 
caterwauling on the other side about Elon Musk. I don't know 
what he has to do with anything today. I listen to all the 
accusations about Russia, Russia, Russia. Boy, I wish we could 
retire that word someday. That has nothing to do with what 
we're talking about.
    I listen to all this nonsense that is being spewed out 
there, and what I can't understand is why anyone wants to 
undermine our criminal or civil justice system in the manner 
that has been done over the last couple of years with lawfare, 
whether you're a Republican or a Democrat.
    Can you understand that, Ms. Foley?
    Ms. Foley. No, absolutely not. If they can do it, one side 
can do it; the other side can do it too.
    Ms. Hageman. Isn't that kind of what happens in our 
political system?
    Ms. Foley. Yes, because it's politics.
    Ms. Hageman. It's politics, that's right.
    Ms. Foley. Politics and law should be different.
    Ms. Hageman. Don't you think that most of the American 
people understand what happened in these cases? Do you really 
think--does anybody really think that anybody was confused or 
that we couldn't figure this out or we didn't even know exactly 
what was happening with these cases in New York and the Fani 
Willis cases.
    We all knew what was happening, right? It was to stop him 
from running for President. Pretty simple to figure out. Isn't 
that a classic example of lawfare? Is that what we want our 
justice system to turn into, again, whether you're a Republican 
or Democrat? Is that what our Constitution is here for?
    Mr. Terwilliger, do you think that that's a good use of our 
criminal justice system?
    Mr. Terwilliger. No, ma'am.
    Ms. Hageman. Well, we have focused a lot on how politically 
motivated the State and local officials can target--have been 
when they target our Federal officials, but we also need to 
consider the Biden DOJ's role in all this that happened.
    For example, Mr. Epstein, what agency has Congress charged 
with adjudicating and enforcing Federal campaign finance 
violations?
    Mr. Epstein. That's the Federal election Commission.
    Ms. Hageman. All right. From a Congressional perspective, 
why shouldn't every Member of this Committee--why should every 
Member of this Committee care about the proper enforcement and 
interpretation of a law Congress drafted? Isn't that our role?
    Mr. Epstein. Absolutely, they should.
    Ms. Hageman. In Mr. Bragg's prosecution, did the Biden DOJ 
enforce its exclusive jurisdiction?
    Mr. Epstein. No. In fact, we know that the Public Integrity 
Section at the Department of Justice has historically 
prosecuted election crimes, and yet here they ceded authority 
to a State prosecutor.
    Ms. Hageman. They allowed a State Court to prosecute a 
former President in a case that the court had no jurisdiction. 
Is that fair?
    Mr. Epstein. Yes. Ms. Congresswoman, it's even worse, 
because we have a tradition of Federal agencies; even if you 
want to say that Federal agencies have expertise in these 
questions, we certainly know that State Courts don't have 
expertise in Federal questions relating to elections.
    Ms. Hageman. They wouldn't have developed it because they 
don't have jurisdiction.
    Mr. Epstein. Exactly. That's the meaning of jurisdiction.
    Ms. Hageman. Then, when you bring in Mr. Colangelo and his 
involvement with this, we know that the Biden Administration 
was knee deep in the prosecution of Mr. Trump in New York, 
don't we?
    Mr. Epstein. Yes. In fact, as America First Legal found 
out, of course, these documents were withheld under privilege 
protections, but 36 records existed of communications between 
the District Attorney of New York, that office, and the 
Attorney General's Office. Yet, Attorney General Garland came 
to this Committee and said that, ``there were no 
communications.''
    Mr. Roy. Thank you, Mr. Epstein.
    Ms. Hageman. Thank you, and I yield back.
    Mr. Roy. I thank the gentlelady from Wyoming.
    I now recognize the gentleman from Tennessee, Mr. Cohen.
    Mr. Cohen. Thank you, Mr. Roy.
    I watched the testimony earlier, and the first part I saw 
was Jim Jordan incorrectly saying a lot of things about 
President Trump. He started with saying that this Mueller 
investigation didn't show anything concerning Trump; there was 
no connection. That's because Bill Barr redacted it and made 
his own opinion of the front end of what the case said, what 
Mueller said.
    Mueller's report made it clear that there was Russian 
involvement. The first thing that the Russians did was to send 
some folks up to Trump Tower to talk to Junior and son-in-law 
and a few other Trumpers and talk about getting something done.
    That woman that came up there to meet with him ended up 
being in the Russian Dumas. Russians must have thought pretty 
well of her. She did her job well.
    The Senate did a study, a bipartisan study on whether there 
was Russian collusion. The Senate Intelligence Committee came 
out and said, ``yes, there was, that Manafort went over to 
France or wherever and met with Kilimnik and gave him the 
polling data and this is where we need help.''
    Then that ended up getting to Prigozhin in St. Petersburg, 
and then they started spewing out all the false social media 
stuff to make Blacks think they shouldn't vote, and other 
people get confused about this and that and trying to help 
Trump.
    That's what they did. The Russians helped Trump get elected 
in 2016. The Senate Intelligence Committee said that, and the 
Mueller Committee said--Mueller report said that.
    Then, as far as this trial goes that you say there's not 
been a President indicted before, there's never been a 
President that was so easy to indict. The guy has committed 
more crimes than all the other Presidents put together.
    Michael Cohen got tried and sent to prison because of what 
he did in this case, but Bill Barr didn't want to try the 
President, who was individual one, basically saying, ``The 
President did it, but we're sending Michael Cohen to jail,'' 
and to protect individual one. That's what they did. He should 
have been tried in Federal Court, but Bill Barr wasn't man 
enough to do it because he was bought.
    The President paid off Stormy Daniels and whatever she was, 
Ms. August, whatever, and paid them off so that it wouldn't 
become public and hurt his Presidential campaign. Michael Cohen 
took the orders that he had to do it, and they did that.
    It was Federal election involvement and criminal law. The 
jury found him guilty. How many counts did they find him--
Professor, how many counts were there that he was found guilty? 
Thirty-four?
    Ms. Beske. Thirty-four.
    Mr. Cohen. Thirty-four times. A jury, Americans, citizens 
voir dired by both sides, chosen, on 34. They all agreed, 34 to 
nothing. Every single one of them said guilty beyond a 
reasonable doubt.
    You all are questioning the American jury system and say, 
because they're in a State Court their ruling wasn't proper. 
You could commit a murder. Hamilton and Burr had their duel in 
New Jersey I guess it was, and there should be a criminal case 
and there was.
    They want it--this whole law is about helping Trump, who's 
still hung up on this guilty verdict, which he's not going to 
spend any time on or even have to pay a fine.
    There's no need for this law. Trump wants to get it in 
Federal Court because he's got friends there and, like Mr. 
Raskin mentioned, Aileen Cannon and what she did, which was 
disgusting all around. She ruined the classified briefs, files 
case, and classified information. He was guilty as hell of 
that. She held it and held it and held it until they can't even 
get the Special Counsel's report out.
    The Supreme Court put the case on January 6th off and off 
and off so it wouldn't be heard. The Supreme Court is also 
involved in this. They were wrong to give Trump a free pass. 
Donald Trump shouldn't make law. He shouldn't do--he shouldn't 
be where he is. That's what happens when you elect someone who 
is emotionally, morally, and intellectually incapable of 
performing the job that they're chosen. You give him a pass 
from DOGE and says, ``You're bad work; you're fired.''
    I yield back.
    Mr. Roy. I thank the gentleman from Tennessee. I find it 
interesting that we're now concerned about the intellectual 
capacity of the President of the United States.
    I'll now recognize the gentleman from North Carolina, Mr. 
Harris.
    Mr. Harris. Thank you, Mr. Chair.
    I thank all of you on the panel for your time today and for 
your testimony.
    Mr. Epstein, on August 8, 2022, the FBI raided Mar-a-Lago, 
and the American people witnessed an unprecedented attack on 
the home of a former President by a politicized FBI.
    Almost a year after the raid on Mar-a-Lago, on June 7, 
2023, Steven D'Antuono, the former Assistant Director in charge 
of the Washington Field Office, sat down with the House 
Judiciary Committee for a transcribed interview as a part of 
this Committee's oversight of the FBI. In the interview, Mr. 
D'Antuono described what he viewed as several abnormalities 
about the way in which that raid was conducted.
    Mr. Epstein, in a notice of claim filed in the DOJ in 2024, 
you argued that the FBI's conduct in the raid, where 
established protocol was violated, ``constitutes a severe and 
unacceptable intrusion that is highly offensive to a reasonable 
person.''
    Would you explain to us today how the FBI's raid of Mar-a-
Lago was inconsistent with standard protocols?
    Mr. Epstein. Well, Congressman, precisely as Mr. D'Antuono 
testified before this Committee. That we have protocols. We let 
the attorneys know before the raid is going to be conducted. We 
typically use the local office to be in charge of it, not the 
Washington Field Office to be in charge of that.
    The protocols here were wholly inconsistent, and I think 
that's part of the concerns about when political goals inform 
what otherwise should be doing justice.
    Mr. Harris. Why do you suppose they opted out of such 
protocols?
    Mr. Epstein. Here the tone was set from the top. I'll just 
note that, on this question of records and what was probable 
cause to do these investigations, so much of that was based off 
the views of the National Archives that these were records that 
were in the proper ownership of the United States.
    In large part because of America First Legal's work, we 
recently showed that the former Archivist of the United States, 
David Ferriero, actually said that we should treat President 
Trump's records as if they were Federal records, and violations 
of the Federal Records Act allows us to make referrals to the 
Department of Justice.
    That was an arbitrary, capricious legal determination that 
led to the ability for the Department of Justice to have 
probable cause to conduct this raid. That's something that is a 
direct piece of evidence of politicization of the law.
    Mr. Harris. Thank you, Mr. Epstein.
    Mr. Terwilliger, your client, Mark Meadows, is being sued 
by Fulton County, originally by the very partisan District 
Attorney Fani Willis. Meadows sought to have his court case 
moved to a Federal Court arguing it was more appropriate 
because he was acting in the official capacity as Trump's White 
House Chief of Staff.
    After his bid was rejected by the Supreme Court, you argued 
that the risk puts former Federal officials such as Meadows, 
quote, ``at risk of being left to the wiles of every 
particularly hostile district attorney or State AG in the 
country.''
    I happen to agree with you. Something needs to be done to 
protect future former officials from being subjected to the 
type of lawfare that Mr. Meadows is facing.
    My question to you, Mr. Terwilliger, does Congress have a 
responsibility to protect Federal officials from lawfare?
    Mr. Terwilliger. Yes, sir, it does. It has tried repeatedly 
to do that. The courts have repeatedly pushed back for whatever 
reason, including in the Mesa v. California decision.
    What Mr. Raskin's comments miss is the fact that all 
Federal Courts, all inferior Federal Courts other than the 
Supreme Court are created by this body, by the U.S. Congress. 
You establish their jurisdiction.
    What I'm suggesting to you very simply to do what you want 
to get done is that you incorporate standard Federal question 
jurisdiction into the removal statute.
    So, in a case like in Mesa, where the question was whether 
or not, if I recall correctly, postal employees could speed or 
not in doing their job, that those questions get decided by 
Federal judges in Federal Courts. Otherwise, we will have an 
incredible body of confusion of State Courts deciding Federal 
questions.
    It is important, because of the Mesa decision, to make 
clear that Federal questions belong in Federal Court. Indeed, 
over the decades, many Federal Courts have said the very reason 
for the removal statute is to have Federal questions decided in 
Federal Court.
    Mr. Harris. Well, thank you, sir. I look forward to our 
markup tomorrow in which this Committee will be taking a look 
at important legislation seeking to address these issues and 
prevent future lawfare.
    Thank you, Mr. Chair.
    Mr. Roy. I thank the gentleman from North Carolina.
    I'll now recognize the gentlelady from Washington for five 
minutes.
    Ms. Jayapal. Thank you, Mr. Chair.
    President Trump has a long and documented history of 
attacking the judiciary simply for following the law. He once 
suggested that a judge who granted class certification in a 
fraud case against Trump University could not be impartial 
because the judge was of Mexican descent. He called other 
judges, quote, ``crooked, corrupt and evil.''
    Most recently, he refused to comply with judicial orders 
blocking the implementation of his unlawful funding freeze. My 
colleagues on the other side have unfortunately endorsed this 
behavior, and now they propose legislation that would further 
empower President Trump to evade accountability in the courts.
    Professor Beske, what effect does this kind of behavior 
toward the judiciary have on the integrity of the court system, 
just briefly?
    Ms. Beske. Well, it takes us into dangerous territory. The 
whole premise of Article III judges is they have life tenure. 
The Framers tried to remove them from the political process. 
The whole idea was to have a body of judges free from political 
considerations. The idea of disobeying a court order, boy, 
that's a Constitutional crisis.
    Ms. Jayapal. It is a Constitutional crisis.
    Ms. Beske. That's terrifying.
    Ms. Jayapal. Yes, it is terrifying. In May 2024, Donald 
Trump was found guilty of 34 felony charges under New York 
State law for falsifying business records to conceal hush money 
payments made to Stormy Daniels.
    Republicans believe that this prosecution was politically 
motivated and corrupt, but they seem to forget about the role 
of a citizen jury, which came to the ultimate unanimous 
conclusion of Donald Trump's guilt after hearing both defense 
and prosecution lay out the arguments.
    Can you just remind us why the Founding Fathers actually 
adopted the jury system, one or two sentences if you can.
    Ms. Beske. That's hard.
    Ms. Jayapal. I know it's tough for a law professor.
    Ms. Beske. That was kind of the genius of the Framers, 
right, to put front and center ordinary citizens there to be 
safeguards against the government to protect and be the 
decisionmakers, right?
    Prosecutors might be motivated to get the conviction, but 
to have the ultimate decisionmakers be people, ordinary people 
who are weighing the evidence and coming to decisions. That was 
kind of their genius.
    Ms. Jayapal. It is genius. There are even some checks and 
balances built into the system to make sure that jury members 
are impartial. What are one or two of those?
    Ms. Beske. Well, you have challenges for the cause. They're 
unlimited typically in every State. Peremptories, there are 
some limits on those but there's voir dire, I mean that--
sequestration. Typically, judges are kept from things--or, 
rather, jurors are kept from things that might prejudice them. 
Judges obviously have the ability to call a mistrial in the 
event there's anything.
    Ms. Jayapal. That's correct. So, there's lots of things 
built-in to make sure that this is a fair process. There was no 
evidence of improper bias or behavior by any members of the 
jury, right, in that criminal case?
    Ms. Beske. No.
    Ms. Jayapal. Once again to confirm, did the citizen jury, 
this genius system that you've described, unanimously conclude 
that Donald Trump was guilty of 34 felony charges?
    Ms. Beske. With respect to each of 34 charges.
    Ms. Jayapal. Each one.
    I want to turn to this legislative proposal, which seeks to 
amend Federal law to allow Presidents to remove cases against 
them from Federal Court to State Court. Under existing law, 
removal is only granted in limited cases. Motions have to be 
made on specific grounds that allow for removal, and one of 
those grounds is that a Federal officer, Member of Congress, or 
judge can remove a case if the case relates to, quote, ``any 
act under color of office.'' The Supreme Court, as you've 
mentioned, has interpreted ``color of office'' to mean acts in 
performance of an official duty.
    The other side's legislation exceeds this requirement by 
allowing Presidents to remove any case to Federal Court for any 
act in office--that's a quote from their legislation--
regardless of whether it relates to exercising their official 
powers.
    Why is it a bad idea to eliminate that, quote, ``color of 
office'' requirement?
    Ms. Beske. Well, you're certainly expanding the possible 
pool--now, again, always qualified by the Mesa Federal defense.
    Ms. Jayapal. Yes.
    Ms. Beske. You're expanding the possible pool of people who 
can take this bridge to Federal Court. I'm a federalism person, 
and I believe that having two sovereigns in our system, States 
and the Federal Government, is a protection against tyranny.
    The Framers really thought about this. That protects 
individual rights, and to take from States their ability to 
prosecute violations of State law in their own courts is very 
intrusive. The more that's allowed, that's a problem in our 
system.
    Ms. Jayapal. Protection against tyranny, that's really what 
we're talking about here. I really appreciate your input.
    I yield back, Mr. Chair.
    Mr. Roy. I will recognize the gentleman from Texas for five 
minutes.
    Mr. Hunt. Thank you, Chair.
    The past few years, the Left has used every weapon, 
including weaponizing the Department of Justice against 
President Trump. Of course, they didn't stop at the DOJ. The 
Left used State and local prosecutors to do their biddings as 
well.
    Do you remember the so-called hush money case in New York? 
This is the case that was led by Matthew Colangelo, the former 
No. 3 at the DOJ. That's right, a high-ranking DOJ official 
left his job to work for a local DA's office. That's pretty 
ridiculous and does not pass the smell test to anybody that's 
competent.
    Of course, there's the so-called RICO case in Georgia, as 
if this guy was Al Capone. Thanks, Fani. Then there's Tish 
James. She ran solely on prosecuting Donald Trump. Now, isn't 
her main job to protect New Yorkers? She was clearly 
distracted. You cannot tell me that these cases were not 
politically motivated. If President Trump were not running for 
President again, none of this would have happened, period. None 
of this would have happened.
    What people have got to understand is that this is really, 
really good for fundraising for Democrats, but I'm going to say 
the quiet part out loud here. They want their veneer of 
legitimacy.
    You may have forgotten this but, again, they threw 
everything at President Trump. They impeached him twice and 
tried to remove his name from the State Presidential ballots. 
They laser focused Lady Justice to eliminate the competition. 
How did he survive this? Because he is clearly not like the 
average person. He is a political force of nature.
    What happened over the course of the past four years to 
President Trump should shock everyone in this country, because 
one thing he would always say on the campaign trail was this: 
If he could do it to me, they could do it to you. I'm just 
standing in their way.
    This is repulsive behavior that we saw from the Left to 
prevent a man from becoming the President of the free world. 
Guess what happened? We the people saw right through the crap, 
and we still made him our 47th President. Thank God for the 
resolve of the American people.
    Mr. Epstein, I have a question for you, sir. Thank you for 
your work to expose weaponization against President Trump. You 
said that the Alvin Bragg case was coordinated with Biden. For 
those of us at home, can you walk us through this process and 
how it happened? Can you explain how Biden and his fingerprints 
were all over this operation?
    Mr. Epstein. Yes. Thank you, Congressman. I wish we could 
tell you what the documents would reveal. That's still up in 
litigation. What we did at America First Legal is we obviously 
used a FOIA request to Main Justice to look for communications 
with the New York District Attorney's Office. The response, 
consistent with what Attorney General Garland said to this 
Committee, was that there were no responsive records.
    So, what we did is what any good investigative lawyer does, 
is you send a similar request to the District Attorney's Office 
in New York, the Manhattan DA, and you say, ``Give us all 
communications with the Department of Justice.''
    While they didn't disclose those records, they said, 
there's 36 responsive records, which suggests that, in fact, 
there were communications. It's important for the public to 
know what was said in those communications.
    Mr. Hunt. Thank you very much for answering the question.
    I also want the American public to understand something. 
The reason why the Left is still railing on President Trump 
even though he won the Presidency, we won the Senate, and we 
were able to keep the Majority in the House is because, quite 
frankly, they have nowhere else to go because its lawfare fell 
flat on its face.
    We cannot allow this to happen again in the future of this 
country. That's why we've got to understand our history and how 
this works. We have to understand that we are a Constitutional 
Republic, and we must protect the average citizen in this 
country, ranging from President Trump to the average person 
that works every day here in America that makes a decent wage 
just taking care of their family. Everybody must be treated 
fairly under the law, regardless of what they do or regardless 
of what they aspire to be.
    With that, I yield back the remainder of my time. Thank 
you, Mr. Chair.
    Mr. Roy. I thank my friend from Texas.
    I now recognize the gentlelady from Vermont.
    Ms. Balint. Thank you, Mr. Chair.
    I want Vermonters to understand the stakes of what's 
happening right now at the Department of Justice. I know many 
Americans feel in this moment that they can't trust government, 
and I certainly understand why they might feel that way.
    Democracies have long struggled with rooting out public 
corruption. As long as there is public trust, there are those 
who will betray the trust for their own power, for their own 
profit. How do we combat corruption? How do we ensure the 
responsible use of power? Those are the things that I think 
about a lot and that my constituents ask me about.
    One of the ways that we do that is by entrusting that we 
have independent, ethical prosecutors to uphold the law no 
matter who is in office.
    I want to acknowledge and thank everyone for being here 
today. I especially want to acknowledge Mr. Terwilliger, who 
previously served the people of Vermont and the Nation under 
the Reagan Administration in various roles, including the U.S. 
Attorney. So, thank you so much for being here.
    Mr. Terwilliger, do you agree that one of the most 
effective ways to fight corruption is to establish and maintain 
a group of nonpartisan prosecutors who are dedicated to the 
rule of law?
    Mr. Terwilliger. I certainly agree with that, ma'am. If 
you'll allow me just 30 seconds, when I was the U.S. attorney 
in Vermont, I had no idea if my assistants were Republicans or 
Democrats. They were people who believed in the rule of law and 
applying the rule of law.
    If one of them had ever come in and said, ``We should go 
after so-and-so because or on account of,'' I sadly have to 
tell you, ma'am--
    Ms. Balint. If I could, if I could just because I only get 
five minutes.
    Mr. Terwilliger. Let me just finish, 10 seconds. I sadly 
have to tell you that culture at the Department of Justice has 
changed completely in the last 10-15 years.
    Ms. Balint. The whole idea--so, to stay with what you're 
saying, the whole idea behind the Department of Justice, right, 
is supposed to be enforcing the law without fear or favor, 
correct?
    That's what the American people want. That's what 
Vermonters want. I hear that from them all the time. That's 
what our Constitution actually demands.
    So, when a U.S. attorney stands before a judge and say that 
they are there not to represent the people, but to represent a 
President, understandably, there are alarm bells that start 
ringing.
    We're two months into this administration. So far, we've 
had a U.S. attorney publicly State that his office is composed 
of President Trump's lawyers, not lawyers for the people, not 
lawyers supporting the Constitution, but President Trump's 
lawyers.
    We've seen political purges of nonpartisan career civil 
servants because they did their jobs, including those who were 
involved in the January 6th prosecutions. We've seen a shocking 
quid pro quo involving the indicted mayor of New York. You said 
so yourself: ``It should not be about partisanship within the 
office.'' I applaud you for that.
    Thank you for being here.
    I'd like to turn now to Professor Beske.
    Professor Beske, under the legislation offered by the 
majority, specifically section 1456(c), the Attorney General 
could represent a Federal official in any case, subject to 
removal under the statute.
    Is it true that this provision could make the Department of 
Justice the personal counsel for the President, the Vice 
President, or for Federal officials in State criminal or civil 
cases? Is there a danger there?
    Ms. Beske. There is certainly a danger, because there are 
typically, the norm is that there's a separation there.
    Ms. Balint. Does that terrify you to contemplate that?
    Ms. Beske. It certainly doesn't help me sleep at night.
    Ms. Balint. OK. All right. I'll take that as in the 
affirmative.
    I do think that it goes strongly against what Americans 
want, what Vermonters want. They want to make sure--without 
fear or favor, they want to make sure we're doing this in a way 
that is not corrupt.
    There is, in fact, what I think another important key 
element here, which is how the public perceives those attorneys 
charged with enforcing the law. How important, again to 
Professor Beske, how important is the public trust in those who 
enforce anticor-
ruption laws?
    Ms. Beske. It's extremely important.
    Ms. Balint. Tell me more.
    Ms. Beske. If the public doesn't have trust in our Federal 
justice system, in the justice system, we don't have very much 
left.
    Ms. Balint. It doesn't hold together, does it?
    Ms. Beske. It doesn't hold together.
    Ms. Balint. It doesn't hold together.
    If the people don't believe that justice is blind, 
anticorruption efforts are doomed to fail, and authoritarians 
thrive in that environment where there is no public trust.
    What my Republican colleagues have done for many years and 
in this Committee as well, they've attacked prosecutors. 
They've attacked judges. They've dragged public servants, 
public servants down here for baseless--in my opinion, baseless 
depositions, sent letters full of baseless accusations, blasted 
theories, many of them hateful, all over the internet.
    What happens then is that Americans become incredibly 
skeptical, cynical about if there is any such thing as a 
justice system without fear or favor, and I think that should 
scare all of us.
    I understand, Mr. Chair, I'm over time. I yield back.
    Mr. Roy. I thank the gentlelady from Vermont.
    I am now going to recognize the gentleman from Missouri, 
Mr. Onder, for five minutes.
    Mr. Onder. Thank you, Mr. Chair. Thank you to all the 
witnesses for being here today.
    Last June, the Attorney General from my home State of 
Missouri appeared before this Committee, Andrew Bailey, and 
testified that Missouri removed a prosecutor who filed 
politically motivated cases while refusing to prosecute violent 
crimes, even murders.
    What the St. Louis prosecutor and Alvin Bragg had in common 
was that their campaigns were funded through the Vera 
Institute, which receives tens of millions of taxpayer dollars, 
as well as funding from George Soros, essentially, being funded 
to not prosecute crimes but to take political actions against 
political opponents, in the case of Ms. Gardner in St. Louis, 
the Governor of the State of Missouri.
    It's no secret, of course, that in New York, Alvin Bragg 
was on a vendetta to prosecute President Trump.
    Mr. Epstein, I wanted to--the Ranking Member said that 
there was, quote, ``no Federal question in Alvin Bragg's case 
in New York.'' I just wanted to run through that briefly. There 
was the allegation, of course, in the New York case that money 
was paid in return for a nondisclosure agreement with Ms. 
Clifford. Is an NDA illegal?
    Mr. Epstein. No.
    Mr. Onder. No. Then, in the course of making that payment, 
somehow the allegation was that business records were 
falsified. As I understand it, that was a misdemeanor with a 
two-year statute of limitations that had expired. Am I correct 
there?
    Mr. Epstein. Yes, Congressman.
    Mr. Onder. OK. If the business records were falsified in 
furtherance of another crime, then the statute of limitations 
wouldn't be expired, and it would be a felony, not a 
misdemeanor. Is that right?
    Mr. Epstein. Right.
    Mr. Onder. Then the question is, what law was violated? 
It's my understanding, as stated earlier in your inquiry with 
Congresswoman Hageman, it's the FECA of 1971, the Federal 
Election Law of 1971.
    Congress invested exclusive jurisdiction over that statute 
with the FEC and the Department of Justice, as I understand it. 
I think that was in your testimony. The FEC looked at the case 
that--looked at that allegation and decided that it was without 
merit, and the New York court did not have jurisdiction over 
that anyway.
    Can you explain again how the issue of campaign finance was 
crucial to this case and was, indeed, a Federal question?
    Mr. Epstein. Yes, I know. Your bewilderment is justified 
and explained by a longstanding principle in our American 
jurisprudence that, when you have an agency like the FEC that 
has expertise in Federal election campaign contributions or 
expenditures, and then you have a State trial judge who has no 
expertise, that our doctrines say that this judge should stay 
the case, refer it to the expert agency, and allow them to 
first adjudicate.
    If they, in this case, look at the facts and determine we 
are not going to act, then you can potentially proceed with a 
further criminal prosecution.
    I can say that the primary jurisdiction doctrine has been 
used in State law prosecutions before to stay those cases. That 
was not something that this court was willing to do.
    Mr. Onder. A federally motivated--I'm sorry, a politically 
motivated prosecutor in front of a politically motivated judge 
in a venue, a jurisdiction where President Trump could not get 
a fair trial shoehorned a Federal statute over which they had 
no jurisdiction or expertise to bring charges against President 
Trump on a very obscure crime.
    It's just absolutely unbelievable. We had the statue of 
Lady Justice being blind. I think justice was anything but 
blind in this case.
    Well, thank you, Mr. Epstein.
    I yield back.
    Mr. Roy. With that, I'll now recognize the gentlelady from 
California, five minutes.
    Ms. Kamlager-Dove. Thank you, Mr. Chair.
    So, Mr. Epstein, I have a yes-or-no question for you. Do 
you believe in due process?
    Mr. Epstein. Yes.
    Ms. Kamlager-Dove. OK, thank you.
    Mr. Terwilliger, another yes-or-no question for you. Do you 
believe in the jury system? Yes or no.
    Mr. Terwilliger. I'm not sure what you mean by believe in 
it. Do I think that it's a good system in our criminal justice 
system? Yes.
    Ms. Kamlager-Dove. OK, thank you.
    Professor Beske, do you believe that the right to a jury 
trial is the very foundation of due process, yes or no?
    Ms. Beske. It is one of the mainstays of our system, both 
civil and criminal.
    Ms. Kamlager-Dove. Absolutely. In fact, our Founding 
Fathers would agree with you, because the right to a jury trial 
is mentioned three times in the Constitution. It's kind of 
important. Not free speech, not even the right to guns, but the 
right to a jury trial and to be judged by your peers. Jury 
trials are, in fact, how we decide conflicts in this country.
    In fact, the President is no stranger to this system. He 
has routinely said, ``I don't want a judge to decide my case. I 
want a jury, because I want it to be fair.''
    So, Professor Beske, are you familiar with the Russian term 
``arbitrazh,'' yes or no?
    Ms. Beske. Arbitrazh?
    Ms. Kamlager-Dove. Yes. It's OK; you can say no.
    Ms. Beske. I know the English term. I'm not sure of the 
Russian term.
    Ms. Kamlager-Dove. The Russian term means the opposite of 
fair. You don't get a trial. You have a case that's decided by 
a so-called professional judge. There's no due process. There's 
no jury of peers. The judges are there to appease the powers 
who put them there. So, in Russia, that means the billionaires.
    Legislative reforms to end lawfare by State and local 
prosecutors is really--let's just say it. It's overburdening 
the Federal Government and taking away State sovereignty at a 
time when Republicans are talking about cutting costs. This 
idea significantly adds more waste, money, resources, and 
confusion to an already weighed-down system, because now you 
want to push lawsuits to the Federal Courts when the vast 
majority of lawsuits involve State interests, State crimes, not 
Federal concerns.
    For example, sexual assault, bribery, and landlords 
threatening tenants, where there's little or no Federal 
statutory equivalent, these cases would be outside of Federal 
jurisprudence. They want to overwhelm the Federal system by 
litigating a State matter in Federal Courts and then force 
Federal judges to interpret States' laws.
    Well, Federal trial courts are not set up to try State law 
cases. What State of jury instruction would they give out, 
State or Federal? An Article III judge is important, because 
they have lifetime appointments, supposedly to free them from 
political affiliations, misgivings, and bias. They have a very 
specific type of jurisdictional bandwidth, and State cases are 
not within it.
    This is how I see the idea going. The President--any 
President's cousin gets into a bar fight and sucker punches a 
man and knocks out his tooth. So, if the bar fight results in a 
civil suit for money damages, the President could pluck the 
case and remove it to Federal Court.
    Now, we want to cherry-pick the litigants ad nauseam, maybe 
only judges with red hats, because the only reason to do any of 
this is to be able to put one's finger on the scale of justice 
and decide the outcome. That's not justice. What that really is 
a merger of the Executive and Judicial Branches, and that is 
not Constitutional here in the United States. The Judicial 
Branch is supposed to be independent. Without an independent 
judiciary, there is no longer a system of checks and balances.
    How does this even make sense at a time when you're talking 
about shrinking the Federal Government? This ineptitude would 
overwhelm the capacity of the Federal judicial system.
    I don't know how many people know what goes into the 
managing of a Federal Courtroom, but there are a lot of people 
who are needed to manage a courtroom. You're going to 
exacerbate the system by increasing its caseload?
    I challenge anyone in this room to find a single Federal 
judge who wants more cases in their courtroom. Their dockets 
are already full. This seems to be a violation of the States' 
rights to handle their own matters. It is a disastrous attempt 
to manipulate the judicial system, and it is a weaponization of 
waste when, in fact, you will have more cases improperly or 
selectively prosecuted.
    My fellow Congress Members, I urge you to get over your 
feelings from the last four years and recommit to the United 
States Constitution. I urge everyone to turn to your neighbor 
and say, ``I don't want my judiciary coopted. I believe in 
State sovereignty. I believe in a jury trial of my peers, and I 
don't want arbitrazh here in this country, because I do not 
speak Russian.''
    With that, I yield back.
    Mr. Roy. I now recognize the gentleman from Wisconsin for 
five minutes.
    Mr. Grothman. Thank you.
    First, I'd like to thank Congressman Roy for having this 
hearing.
    We're dealing with a very serious matter and scary matter. 
I don't know if people on the other side of the aisle know it, 
but, right now, if I show up at your average Lincoln Day Dinner 
filled with Republicans or a room full of people who are 
primarily Republican, they think what happened in Georgia and 
what happened in New York is just a joke. They have zero 
confidence, for example, in the New York justice system. I 
don't like the fact that we're there, but I think that is what 
people think, and I'm one of those people who thinks that way.
    By the way, it goes beyond the justice system. I think the 
same way about the IRS. They think the same way about our 
customs system. They just think today the Federal Government is 
something that I would have guessed was from some banana 
republic growing up.
    The first question can be for any one of you: Do any of you 
know any situation other than what just happened in this 
country in which a former Chief of State was charged with 
crimes and at one point appeared to be facing prison time after 
they were removed from office anywhere in the world?
    Ms. Foley. Venezuela.
    Mr. Grothman. Venezuela. OK. Well, we're headed toward 
Venezuela. Anybody else can think of any time around the world 
in which--
    Mr. Terwilliger. Well, your description, sir, of what many 
people think is the degradation of our system, there are many 
examples of it around the world. You have Pakistan, for 
example, where it seems like every other President is either 
assassinated or prosecuted, and then the Judges of the Supreme 
Court are themselves prosecuted and investigated.
    It's what I was trying to explain to the gentlelady of 
Vermont. We used to have a Justice Department where there 
wasn't fear or favor, where politics didn't play. Those days 
are long gone.
    Mr. Grothman. Right. Kind of scary. I agree with you 
entirely.
    A general question I guess for Mr. Epstein: How does the 
lawfare impact the broader relationship between State and 
Federal Governments, particularly in terms of Constitutional 
authority and separation of powers? I should also say, how does 
it affect how the American people view their government?
    I mean, we know to a certain extent just the fact that 
Donald Trump won the election that people, they just felt being 
prosecuted by a court in New York was completely meaningless, 
but go ahead.
    Mr. Epstein. Yes, Congressman, I think the American people, 
who the Constitution was written for them, well understand that 
Federal questions are within the Federal sphere, and State 
questions are within the State sphere.
    The test is, if a legal question can be appropriate, if not 
more appropriate, for a Federal Court, that's where it belongs, 
not a State Court.
    Mr. Grothman. I'll give you three guys a question because 
you all hang around with lawyers. Do you know anybody among the 
lawyers you hang around with who considered what happened in 
New York a serious--something to be taken seriously, something 
to be taken as other than just a trumped-up political 
persecution to try to prevent Donald Trump from being elected?
    How do your lawyer friends when they hear about this case 
in the paper, what do they think of it? Do they think, oh, my 
goodness, well--
    Mr. Terwilliger. I guess the ones I hang out with wouldn't 
be expected to extol the virtues of that process if--even 
assuming there were any, sir.
    Your point is the essential one. Regardless of what lawyers 
think, people look at that, and commonsense tells you this was 
a travesty of justice.
    The gentlelady can talk about the jury system, but if you 
cannot admit, based on 200-and-some odd years of our history, 
that juries make major mistakes--
    Mr. Grothman. We're in a moral free fall in this country. 
Juries and apparently prosecutors in New York, just say, ``I've 
got power here today; I'm going to harm a politician I don't 
like.''
    Is that what you were going to say, Mr. Epstein?
    Mr. Epstein. Well, what I was going to say is juries are 
great in theory, but a lot of what a jury does depend on 
instructions that come from the judge.
    If you have judges who view their role as political or who 
believe that the ends justify the means in terms of what 
prosecutors are pursuing, they're going to give instructions 
that are limited, that are problematic.
    The Federal Courts, certainly, have had numerous examples 
of where there becomes judicial review of jury instructions 
that raise substantial issues for a defendant's rights. If you 
think about the President in the State Court system, that 
remedy wasn't necessarily available to him.
    Mr. Grothman. Thank you much. We're about where Venezuela 
would be. Thank you again.
    Mr. Roy. I thank the gentleman from Wisconsin.
    I now recognize the gentleman from New York for five 
minutes.
    Mr. Goldman. I will just say, as a Representative of New 
York, New York City, and a former prosecutor in New York, I 
resent and object to the insinuation from my colleagues on the 
other side of the aisle that a jury of 12 New Yorkers cannot 
issue a fair and impartial verdict.
    I'm sure that, if I said a jury in Wisconsin could not 
issue a fair and impartial verdict because a defendant was a 
Democrat, you would object too. You should, because it's 
baseless.
    All these accusations about lawfare that we hear over and 
over and over again have no evidence to support it. You say the 
judge in that trial was politically motivated. Why? You say the 
judge was motivated. Is it because his daughter works for a 
fundraising, digital fundraising firm that all of a sudden 
that's politically motivated, that the jury, he can't get a 
fair trial now in New York? Give me a break.
    Mr. Terwilliger, did you read the search warrant for Mar-a-
Lago?
    Mr. Terwilliger. I might have read parts of it. I don't 
know that I read the whole thing.
    Mr. Goldman. You spent 15 years in the Justice Department 
as a prosecutor. I spent 10. I left seven years ago. I hear you 
say that, in the last 10-15 years it's been completely 
politicized.
    I have no idea what you're talking about. When I was there, 
I didn't--just like you, I had no idea the political leanings 
of my colleagues, of the FBI agents I worked with.
    I appreciate your accusations. Maybe, after my five minutes 
since I don't have time, I'd love to hear why you think that 
all the sudden 15 years ago the Department of Justice changed.
    If you read that search warrant and you were a Deputy 
Attorney General and you were asked to review that, would you 
say that this did not have probable cause?
    Mr. Terwilliger. I would assume, without my having read it, 
that a magistrate signed it and determined that there was 
probable cause. I don't think--
    Mr. Goldman. Well, that's obvious. I'm asking you.
    Mr. Terwilliger. That's not either here or there.
    Mr. Goldman. Well, it is. See, this is why it is, Mr. 
Terwilliger, because this is the accusations and allegations 
from my colleagues on the other side of the aisle, that the 
search of Mar-a-Lago for classified documents after Donald 
Trump repeatedly and persistently obstructed justice, 
obstructed an investigation, held onto classified documents, 
lied about it, told his lawyer to lie about it, that all of a 
sudden that search warrant is unprecedented and must be lawfare 
and politically motivated. Wrong.
    I don't have a question for you right now, Mr. Terwilliger, 
but I will because I want to know, and I want to focus on the 
here and now. I want to focus on the last six weeks. You were a 
Deputy Attorney General, correct, Mr. Terwilliger?
    Mr. Terwilliger. Yes.
    Mr. Goldman. It was under the George H.W. Bush 
Administration. You spent 15 years. You may be Republican now 
or were then. I'm sure it had no impact on the job you did. 
You're here as a Republican-called witness.
    Let me ask you something: As Deputy Attorney General, did 
you ever appear yourself in court, because no one underneath 
you would actually appear in court to represent the Department 
of Justice?
    Mr. Terwilliger. I don't recall having to do that, but I 
would have if I had to.
    Mr. Goldman. OK. I don't know what that means, but you 
never did that.
    Have you ever heard of any Deputy Attorney General doing 
that before the last three weeks?
    Mr. Terwilliger. I actually do have some recollection of 
that, but it's not sufficiently clear for me to be able to give 
you that. Probably not.
    Mr. Goldman. Fair enough. Maybe you're right. It was quite 
remarkable that the Acting Deputy Attorney General, Emil Bove, 
had to appear in the Southern District of New York himself as 
the Deputy Attorney General, because seven prosecutors 
underneath him resigned rather than defend a plea agreement 
that he put in writing was not based on the facts, evidence, or 
the law.
    Mr. Terwilliger, I'm sure you'll agree with me that the 
only job that the Department of Justice has is to follow the 
facts, evidence, and the law. Is that right?
    Mr. Terwilliger. I would agree with that. I would also say, 
sir, that district attorneys have a duty to follow their 
orders.
    Mr. Goldman. OK, I got to cutoff. Mr. Terwilliger, I didn't 
ask you another question.
    The other problem we have here is the U.S. Attorney in 
Washington, DC. Unfortunately, I don't have enough time to get 
into him.
    To say that I am the President's lawyer, I hope you 
recognize, Mr. Terwilliger, as someone who cares about the 
Department of Justice, that this undermines the entire law 
enforcement system more than anything that anyone else prior to 
January of this year has ever done.
    I yield back.
    Mr. Roy. I thank the gentleman from New York.
    I'd recognize the Ranking Member.
    Ms. Scanlon. Yes. I have a couple of unanimous consent 
requests. First, I would ask unanimous consent to enter into 
the record an excerpt from the Committee's transcripted 
interview with Steven D'Antuono, former Assistant Director of 
FBI Washington Field Office, on June 7, 2023, in which he 
explained that the FBI executed a search warrant for classified 
material at Mar-a-Lago because there was probable cause to 
believe that Donald Trump did not fully comply with the 
subpoena to turn over classified documents.
    Mr. Roy. Without objection.
    Ms. Scanlon. OK. I also would ask unanimous consent to 
enter into the record another excerpt from the transcribed 
interview with Steven D'Antuono in which Mr. D'Antuono 
explained that he would describe the search of Mar-a-Lago not 
as a raid but as a lawful search pursuant to warrant.
    Mr. Roy. Without objection.
    Mr. Goldman. Mr. Chair, I have a unanimous consent request.
    Mr. Roy. Briefly.
    Mr. Goldman. I'd like to introduce a The New York Times 
article, dated yesterday, entitled ``U.S. Attorney rebuffed by 
Justice Department in push to escalate inquiry into Schumer,'' 
related to Ed Martin, the Acting U.S. Attorney in Washington.
    Mr. Roy. Without objection.
    Mr. Goldman. Then one more. I have a letter, dated February 
12, 2025, signed by me and six other former DOJ lawyers to the 
inspector general, Michael Horowitz, asking him to investigate 
Acting Deputy Attorney General Bove and Acting U.S. Attorney--
    Mr. Roy. Without objection.
    Mr. Goldman. Thank you.
    Mr. Roy. I now recognize the gentleman from Texas, Mr. 
Gill, for five minutes.
    Ms. Gill. Thank you, Mr. Chair.
    Lawfare is antithetical to the American experiment. It's 
explicitly contrary to the rule of law. Yet, it seems to have 
been the Democrats' last ditch effort to win the 2024 election 
cycle.
    In the lead-up to the 2024 election, Democrats knew that 
they couldn't fairly win. They were running a candidate whose 
cognitive State was in question, that was declining before our 
very eyes on national TV while they were trying to tell us that 
he was sharper than ever.
    Their political strategy reminds me of the line in Orwell's 
``1984,'' which was the party told you to reject the evidence 
of your eyes and ears. It was their final, most essential 
command. That was consistent with the Left's messaging. They 
were trying to tell the American people, for instance, that 
defunding the police makes our communities safer, that men can 
get pregnant and should be sharing locker rooms with our 
daughters, and that flooding our country with millions of cheap 
serf laborers would be somehow economically beneficial to our 
working class.
    To get over this messaging issue, they attempted to, again, 
flood the country with people that they thought would 
eventually become Democrat voters, knowing even now that our 
election system had legitimate vulnerabilities to it.
    They directed social media companies to censor lawful 
speech of American citizens and illegally put President Trump 
behind bars for made-up Federal charges in an attempt to 
prevent him from getting back into the White House.
    What we witnessed was a grotesque exercise of raw political 
power by the Democrats against their enemies. That's why I'm 
excited about our markup tomorrow. We've got a series of bills 
that I think are a good first step in helping ensure this 
lawfare doesn't happen again.
    I want to talk about one instance in particular, which was 
Democrats calling upon corrupt State-level officials to peruse 
State-level lawfare and punish President Trump and the millions 
of Americans who supported his campaign. Their one last hope 
leading up to the election was to concoct a novel legal theory 
by Manhattan DA Alvin Bragg. Alvin Bragg in the State of New 
York didn't have jurisdiction to hear this case. They knew that 
moving forward would violate the settled Supreme Court 
doctrine, but, again, this was their last best hope.
    The State of New York, with Democrat donor Judge Juan 
Merchan overseeing the case, finally got their wish. They 
landed a conviction of the President. The American people knew 
it was a sham, and now they know the lengths to which the other 
side of the aisle will go to attack their political opposition.
    Mr. Epstein, thank you so much for being here. We really 
appreciate it and appreciate your work to restore law and order 
in this country. I want to ask you a couple of questions.
    The charges in the case against President Trump in New York 
largely revolved around the Federal election Campaign Act. Is 
that correct?
    Mr. Epstein. Yes, Congressman.
    Mr. Gill. That act grants exclusive jurisdiction over 
Federal election issues to the FEC and the DOJ. Is that 
correct?
    Mr. Epstein. That's correct.
    Mr. Gill. Did the State of New York and DA Bragg have any 
jurisdiction over those supposed campaign finance violations?
    Mr. Epstein. No. In fact, Congressman, I would point out 
that President Trump, during his first administration, made 
disclosures about payments in his financial disclosures, which 
is clear evidence that's a kind of Federal nexus and it's 
wholly within not just the FEC but the Office of Government 
Ethics.
    Mr. Gill. Alvin Bragg was certainly aware he was pursuing a 
frivolous case here, yet he decided to very aggressively and 
very publicly move forward with support from the Biden DOJ.
    What motive do you think, or would you ascribe to Bragg to 
move forward with such a clearly baseless case?
    Mr. Epstein. I can't speculate on what his motives were, 
but I think enough is spoken by how the American people 
recently determined who should be the President of the United 
States. That there is a general view in the public mood of the 
American public that looking to prosecute political enemies 
raises serious concerns about not just the law but what culture 
do we want in America.
    Mr. Gill. I agree. Thank you, Mr. Epstein.
    With that, Mr. Chair, I yield back.
    Mr. Raskin. Mr. Chair, a UC request. This is from Reuters, 
January 20, ``Who has Donald Trump threatened to criminally 
prosecute as President?''
    Mr. Roy. Without objection.
    Mr. Raskin. Thank you.
    Mr. Roy. I would now recognize the Ranking Member for five 
minutes.
    Chair Jordan. I thank the Chair. Mr. Epstein, it backfired, 
didn't it?
    Mr. Roy. Wait, Mr. Jordan--
    Mr. Epstein. Yes, sir.
    Mr. Roy. Who was it, Mr. Gill who went last? Then, it's the 
Ranking Member.
    Chair Jordan. Oh, I'm sorry.
    Mr. Roy. I'm sorry, Mr. Jordan.
    So, now I'll recognize the Ranking Member, Ms. Scanlon, for 
five minutes.
    Ms. Scanlon. Thank you. Thank you very much.
    Sometimes things get a little more complicated around here 
than they should be. We're dealing now with a fairly complex 
statute, basic core Constitutional principles and civil and 
criminal procedure. Gets pretty far in the weeds. Of course, 
there is a really simple way to prevent States from bringing 
criminal charges against Presidents and former Presidents, and 
that is, of course, for Presidents and former Presidents not to 
commit prosecutable crimes, and that's been something that's 
served our country really well with one notable exception.
    Since we are here on this bill, Professor Beske, you 
explained in your testimony that this bill has the potential to 
expand the Federal officer removal statute to encompass purely 
private lawsuits based on personal conduct rather than official 
duties. I know my colleagues across the aisle are very 
concerned about the importance of federalism, but it seems like 
this bill threatens to undercut that federalism, and the 
Constitutional division of power. Can you talk more about that 
provision?
    Ms. Beske. Yes. I'm looking at provision--
    Ms. Scanlon. I think it's Section 2(a)(2) of the bill that 
would add section 5.
    Ms. Beske. Yes. Section 5, which permits removal of any 
action against the President or Vice President where the State 
Court's consideration will hinder, burden, or delay the 
execution of the duties of the President or Vice President.
    This applies on its face only to sitting Presidents and 
Vice Presidents. Of course, we have a norm that we don't charge 
sitting Presidents and Vice Presidents with criminal conduct. 
There's a Supreme Court opinion that says they are immune from 
suits for civil conduct that is official. So, not criminal. Not 
civil conduct that's official. The only thing that's left is 
civil conduct that is personal, private.
    Essentially, the way I'm reading this, the only thing left 
on the table is this proposed bill adds permitting removal of 
actions against the President or Vice President where the State 
Court's consideration may interfere, hinder, burden, or delay 
private suits and--OK. The Supreme Court has specifically said 
private suits--for example, Clinton v. Jones said you can 
totally sue the President during Clinton's term. He asked for 
temporary immunity, and the Supreme Court said. ``no.'' You can 
sue President Clinton during his term, no temporary immunity 
granted. This appears to expand and say, sorry, we're going to 
allow removal when a court determines that it might interfere.
    Ms. Scanlon. OK. That would be with respect to a President, 
a sitting President, or Vice President. So, basically--
    Ms. Beske. Private suits.
    Ms. Scanlon. --simply the act of being President would give 
him a pass on everything.
    Ms. Beske. The Trump University suits and Clinton v. Jones 
suits. That's a big, huge expansion.
    Ms. Scanlon. Sure. There's another provision in here that I 
found really troubling. It says--it's section (d)--``No court 
may define or limit the scope of duties of an official of the 
Executive Office of the President.''
    That would mean that no court could decide--that only the 
President could decide what were the President's official 
duties. How does that square with our Constitution?
    Ms. Beske. Well, what it does is basically read the color 
of office requirement out of the statute, because how can you 
decide what is--whether someone's active within the color of 
their office if you can't ask, well, what is their office? What 
does it entail? What's within and without the scope of their 
duties? It seems to be saying you can't look at what their 
duties entail. If you can't look at what their duties entail, 
you sort of can't answer that question. If you can't answer it, 
then it's not really an element.
    Ms. Scanlon. Well, then doesn't that really strike at the 
core idea of checks and balances, the different branches of 
government acting as checks and balances, if the courts are 
forbidden from determining whether or not something is within 
the duties of the President?
    Ms. Beske. Well, it certainly removes that question from 
the court's purview altogether. What it also does is it greatly 
expands the number of cases that you are resting from State 
Courts and, in theory, allowing into Federal Courts. So, for 
me, it raises some serious federalism issues and that's 
problematic.
    Ms. Scanlon. OK. Feels like it's an ultimate get-out-of-
jail-free card.
    It looks like my time's expired, so I'll yield back.
    Mr. Roy. I thank the gentlelady from Pennsylvania.
    I'll now recognize the Chair of the Committee, Mr. Jordan, 
for five minutes.
    Chair Jordan. Thank you, Mr. Chair. It backfired, didn't 
it, Mr. Epstein?
    Mr. Epstein. Yes, sir.
    Chair Jordan. The gentleman from New York, our colleague on 
the other side, talked about he trusts 12 jurors in New York, 
but the real jury was the 330 million Americans. We the people 
are the ultimate jury in our great country.
    You think about what did--I love the list you put together, 
on page 1 or 2 here of your testimony. It was the dossier--
false dossier that they took to a secret court to get a warrant 
to spy on a Presidential campaign. That wasn't enough. The 
Mueller investigation--they could do all the Trump-Russia 
Mueller investigation--finds no collusion and no coordination, 
none whatsoever.
    Then they raid his home, part of the Jack Smith 
investigation, Alvin Bragg, Fani Willis, the other Jack Smith 
investigation, the 14th Amendment, and the American people saw 
through it all. They saw through it all because it was lawfare. 
The Democrats' argument seems to me to be, oh, criticizing 
lawfare is worse than the lawfare itself. It's just not what it 
is.
    Tell me this--part of this lawfare and some of the details. 
Who's Matthew Colangelo?
    Mr. Epstein. Matthew Colangelo was an Acting Associate 
Attorney General in the Garland Department of Justice who then 
moved to the Manhattan DA's Office to work on the Bragg 
prosecution.
    Chair Jordan. What did he do before he was at the 
Department of Justice? Where did Matthew Colangelo work prior 
to that?
    Mr. Epstein. I don't recall.
    Chair Jordan. I think it was the New York Attorney 
General's Office, wasn't it?
    Mr. Epstein. OK. Makes sense.
    Chair Jordan. Tish James' office. Here's a guy who worked 
for Tish James, then worked for the Biden-Garland Justice 
Department, and then Alvin Bragg says we want him to work for 
us. According to media, he came to work for Alvin Bragg for 
what reason? I think you put it in your testimony.
    Mr. Epstein. Yes. He obviously was motivated by the case 
against President Trump.
    Chair Jordan. Yes. To jumpstart their investigation, is the 
term that was used in the press.
    We asked for any communications between Alvin Bragg and the 
Biden Justice Department, and they said we've looked, and we 
can't find any. You disagree with that. You disagree with what 
Mr. Garland told this Committee, the House Judiciary Committee. 
You disagree with that. Tell me why you disagree with that.
    Mr. Epstein. Well, it's not just a question of 
disagreement. It's a question of facts. The New York Manhattan 
DA's Office let America First Legal know that there were 36 
responsive records.
    Chair Jordan. When Merrick Garland told this Committee we 
can't find anything, that wasn't accurate, was it?
    Mr. Epstein. I'll let this Committee make that inference, 
but it seems so.
    Chair Jordan. Wasn't accurate based on what Alvin Bragg 
told the court, right?
    Mr. Epstein. Correct.
    Chair Jordan. Well, go figure. We'd like that information. 
That's going to be the next thing we ask Attorney General 
Bondi, if we can get access to some of those 36 responsive 
records that you talked about.
    Now, Mr. Terwilliger, this legislation that we're talking 
about where you can take the case to Federal Court when you got 
some State and local prosecutor coming after a Federal 
official, it's not just for Republicans, is it?
    Mr. Terwilliger. It's certainly not. In fact, both as to 
formers and as to the reinstalling the substantive scope, 
expanded scope that Congress intended going back to at least 
2011, every former official of the Biden Administration would 
cheer you on.
    Chair Jordan. Yes. It's just as important for if some 
prosecutor in Arkansas, Oklahoma, some Red State decides, for 
whatever reason, he's going to--I'm assuming based on the facts 
and the evidence, but let's say it's maybe a little shaky. 
Maybe not. Maybe it's a great case. Still, we're saying OK to 
the Chief of Staff of President Biden, Mr. Zients, if they're 
coming after you, you can move that to Federal Court. You don't 
have to go into some State Court in a Red State. You can go to 
Federal Court. It applies across the board because we want 
equal treatment under the law in this great country.
    Mr. Terwilliger. So true, Mr. Jordan. The fact of the 
matter is that I really would urge, particularly your 
colleagues on the other side of the aisle on this Committee, to 
go back and look at what those two Democrat-appointed 
Presidential judges said in the 11th Circuit Case. They 
recognized just how perniciously dangerous it is. What is a 
Chief of Staff supposed to do when the President says, I want 
you to set up a phone call. I need to talk to so-and-so. Oh, 
wait a minute. Am I going to get in trouble with Fani Willis 
because I do this?
    Chair Jordan. Yes.
    Mr. Terwilliger. It's absurd.
    Chair Jordan. No, it's absurd. That's absurd. Just the 
overall attack on Executive privilege, for goodness' sake. This 
goes clear back to George Washington. Something we have 
honored.
    The people most close to the President are the White House 
Counsel and his Chief of Staff, and they've always had that 
privilege there until now. In their effort to get President 
Trump, they said we're going to violate something that's been 
around since Washington, and they did this. What we're saying 
is let's at least fix it so that you can go to Federal Court, 
fix part of it so that you can go to a jury that's different 
than some local prosecution, some jury at a local level.
    Mr. Terwilliger. Yes, sir. These are quintessential Federal 
questions that have to be brought into Federal Court.
    Chair Jordan. I thank the Chair and our witnesses for--I'm 
sorry, Professor Foley. I didn't get to you. I usually like to 
try to get a question to all our witnesses in these type of 
hearings.
    With that, I will yield back to the Chair.
    Mr. Roy. I thank the Chair of the Full Committee, Mr. 
Jordan.
    I'll now recognize myself for five minutes for questions.
    One thing that was raised earlier a little bit is about how 
15 years ago, the DOJ may have gotten a little bit politicized. 
Mr. Terwilliger, you were referencing to that.
    I served in the Department of Justice about 15 years ago--
right on the number--when I was a Special Assistant United 
States Attorney. One thing that I would note--Jack Smith has 
been at the center of a lot of these issues and debates in 
terms of lawfare. Obviously, that's in the Federal context. 
When he entered his role as Special Counsel, Smith had already 
had a pattern of targeting Republican politicians.
    For example, in 2013, when he served as the head of DOJ's 
Public Integrity Section, Jack Smith encouraged his 
subordinates to contact IRS official Lois Lerner to discuss how 
the Federal Government could bring charges against conservative 
nonprofit organizations.
    Was that a depoliticized Department of Justice, Mr. 
Terwilliger?
    Mr. Terwilliger. No, sir. You've hit right on it. When you 
use your commonsense to look at what's happened. When you see 
some of the former prosecutors that were involved in some of 
these cases showing up as commentators on MSNBC, spouting 
political rhetoric, you don't have to be a genius to figure out 
what happened at the Department.
    Mr. Roy. It's not the only example, right? We can go down 
Lois Lerner. We can go down a whole bunch of different 
possibilities. How about Eric Holder himself with Fast and 
Furious? Wasn't like the Department of Justice was looking to 
go dive deeply into what was going on with respect to 
specifically what Eric Holder did.
    Mr. Terwilliger. I love that example, Mr. Roy, because can 
you imagine if Pam Bondi stood up today and described herself 
as Donald Trump's wingman as Eric Holder described himself for 
President Obama?
    Mr. Roy. Well, you can see why I was only a Special 
Assistant U.S. Attorney for a couple of years during the Holder 
era and decided to move on and work for Governor Perry down in 
Austin.
    Let me tell you something--let me ask you this question. 
You've cited the two members of the 11th Circuit panel, right. 
They concurred in the result, but they raised this issue. Is 
that right?
    Mr. Terwilliger. That's correct.
    Mr. Roy. The issue they raised--and I'm quoting,

        In short, foreclosing removal when States prosecute former 
        Federal officers simply for performing their official duties 
        can allow a rogue State's weaponization of the prosecution 
        power to go unchecked and to fester.

Is that a correct quotation?
    Mr. Terwilliger. That is correct, yes, sir.
    Mr. Roy. You share that concern, do you not?
    Mr. Terwilliger. Absolutely.
    Mr. Roy. Could you just describe a little bit--we've 
discussed it at some length here, but as we take up this 
legislation, at the heart of it lies the question that was 
going on here in the exchange between the Ranking Member and 
Professor Beske and some others about the job and the nature of 
the job.
    If you're in the case of your client, the Chief of Staff to 
the President of the United States, and the President of the 
United States asks you to set up a call--and there's the 
inherent blend between official and political in what we do, 
right. Something we see as official, you're the Chief of Staff 
and working through it, then there's some political questions 
that come up.
    How is it that we can proceed if we don't have clarity with 
respect to the actual job with respect to how you were 
describing that earlier? Can you expand on that a little bit?
    Mr. Terwilliger. Well, I would submit to you, Mr. Roy, that 
there is absolute clarity in terms of that job. In 1939, 
Congress passed a statute and said, OK, ``we're authorizing 
assistants to the President.'' Never existed before. Before 
that, they had always been borrowed from agencies and brought 
into the White House. Presidential Assistants were authorized 
by Congress, and Congress said their duty shall, quote, ``be as 
prescribed by the President.''
    When the President asks you to make a phone call, you're 
acting within the scope of your office.
    Mr. Roy. Do you think it would be good for the country were 
it to be true that, for example, some, I don't know, pretty 
aggressive district attorneys in South Texas or maybe in 
working coordination with the Attorney General of Texas decided 
to say, you know what, we think that the actions of--maybe it 
was DH Secretary Mayorkas, maybe it was the Attorney General--
maybe their actions in leaving the borders wide open to 
endanger Texans was actually in violation of law. Maybe they 
should be prosecuted under Texas law because of what they did 
to the people of the State of Texas, the people in my district 
who are no longer alive, the people who have suffered, the $11 
billion we've had to spend in Texas.
    Do you think it's a good direction for us to go to have it 
such that State DAs and State Attorneys General can then go 
after officials in their--carrying out their official capacity 
and the ranges around that official capacity? Do you think 
that's a good thing or a bad thing, and do you think it's 
important for us to clarify that law?
    Mr. Terwilliger. It's a terrible thing to go in that 
direction, but that's the direction it's going. It is 
inevitable that the worm will turn and there will be Democrat 
officials of political appointees who will be subject of just 
the kind of action you describe.
    This is a place for Congress to assert itself and to say, 
just as the title of this statute says, we want to try to end 
this kind of lawfare. We may not be able to do it completely, 
we may not be able to do it perfectly, but it's a very, very 
important step.
    Mr. Roy. Thank you, Mr. Terwilliger. Thank you to the 
witnesses. I think the Chair of the Committee seeks 
recognition.
    Chair Jordan. If I could, if the Chair would indulge, I 
have one other question.
    Mr. Roy. I would be happy to--
    Chair Jordan. Give an extra question to the Ranking Member?
    Mr. Roy. I would be happy to ask you another question if 
you'd like it.
    Ms. Scanlon. Go ahead.
    Mr. Roy. Yes, sir.
    Chair Jordan. Just wanted to underscore a subject we got in 
right at the end of my five minutes with Mr. Terwilliger.
    Mr. Terwilliger, why do we have Executive Privilege?
    Mr. Terwilliger. It's an excellent question. Because the 
President needs the most candid possible advice that he can 
get, and his aides have to know that if they say, no, Mr. 
President, that's a really dumb idea, that this communication 
is going to be privileged and protected.
    Chair Jordan. Who ultimately benefits from Executive 
Privilege, though? Who's the prim---
    Mr. Terwilliger. The people. The people.
    Chair Jordan. We the people. Exactly. It doesn't exist to 
protect the President or his staff. It exists for us, for the 
American people. We the people. That's why you want candid 
communications to take place between the top officials in the 
West Wing, so they can make decisions that benefit ``We the 
People.''
    The Left has said we want Donald Trump so bad, we're 
willing to forgo that, hurt the people so we can get President 
Trump. Thank the Good Lord it didn't work.
    I yield back.
    Mr. Roy. I'll recognize the Ranking Member for--the 
gentleman used about a minute--for a question that's along 
those lines.
    Ms. Scanlon. Oh, I have to ask a question, not just make a 
screed? OK.
    Mr. Roy. You can use your minute as you see fit--as the 
Ranking Member sees fit.
    Ms. Scanlon. Can we just bring this back to maybe why we're 
supposed to be here?
    We're looking at this statute, Professor Beske. Why did the 
Supreme Court in Mesa say that Federal officers have to have a 
colorable Federal offense, and what would this statute do to 
it?
    Ms. Beske. That's because of Article III. Article III--we 
live in a system of enumerated powers per the Constitution. 
Just like Congress has a list of things it can do under Article 
I, so, too, there's a list of things that courts can do, and 
that's Article III.
    Even though you have power to confer on lower Federal 
Courts what they get to do and whether they exist, you are bet 
on by Article III, and they have to have a Federal ingredient. 
That Federal ingredient is--as Mesa said, ``that Federal 
ingredient is the colorable Federal defense.'' Mesa said here's 
what it's not. It's not just you have a Federal job and this is 
one of your Federal job's duties. Mesa rejected that.
    Ms. Scanlon. It's pretty well established. This attempt 
would expand Federal jurisdiction beyond Article III 
boundaries, and that's why we suggest everyone should oppose 
it.
    I yield back.
    Mr. Roy. I thank the gentlelady. I thank her for her 
indulgence. I tried to recognize you equally.
    I appreciate the witnesses. This concludes today's hearing. 
We thank the witnesses for appearing before the Subcommittee.
    Without objection, all Members will have five legislative 
day to submit additional written questions for the witnesses or 
additional materials for the record.
    Without objection, the hearing is adjourned.
    [Whereupon, at 4:41 p.m., the Subcommittee was adjourned.]

    All materials submitted for the record by Members of the 
Subcommittee on the Constitution and Limited Government can
be found at: https://docs.house.gov/Committee/Calendar/ByEvent 
.aspx?EventID=117974.

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