It has become commonplace for commentators to suggest that, in the aftermath of the Senate's acquittal of President William Jefferson Clinton, there have been only losers and no real winners. Whether this is true generally is a difficult question to which I will not hazard an answer. It is beyond question, however, that one device that lost ground as a result of the storm of impeachment was censure. That censure has taken a severe beating is unfortunate because so much of the beating was based on misguided interpretations of, or arguments about, the Constitution.
Michael J. Gerhardt,
The Constitutionality of Censure,
U. Rich. L. Rev.
Available at: http://scholarship.richmond.edu/lawreview/vol33/iss1/4