Impeachment to death sentences

From impeachment to death sentences: How other countries punish wayward leaders

Other countries remove their leaders too. Some are a bit merciless.

By RYAN HEATH

President Donald Trump thinks he’s suffered more injustice than the alleged witches of Salem, but it could be worse.

Pakistan’s former president, Pervez Musharraf, faced possible impeachment in 2008, leading to his resignation. In the end — earlier this week — Musharraf was sentenced to death for treason.

At the other end of the spectrum, Trump isn’t even the first leader to face impeachment this month. That (dis)honor belongs to Carrie Lam, the chief executive of Hong Kong.

Lam survived a Dec. 5 impeachment vote by a margin of 36 to 26, but need not have worried too much. The vote was an intermediate step and the Communist Party hierarchy in Beijing would likely have stepped in to end the process if she had lost. That’s a luxury Trump won’t have if his impending Senate trial goes unexpectedly awry.

The travails of Trump, Musharraf and Lam raise the question of how countries around the world offer lawmakers and citizens the chance to remove high-office holders from their positions.

In parliamentary systems, a national government leader can typically be replaced for any reason if they have lost the confidence of a majority of members of the lower house of parliament (the equivalent of the U.S. House of Representatives).

American-style presidential impeachment exists in countries including India, Brazil, Russia, France, Germany, South Korea, Philippines, Austria, Hungary, Bulgaria and Ireland.

While American lawmakers now have impeached a president three times, the world leader in impeachment is Norway, which modeled its system after the United States’ and had invoked impeachment eight times before 1927, until the constitutional mechanism fell into disuse following a failed attempt to impeach the prime minister and six members of his Cabinet.

Brazil offers the most recent example of a successful presidential impeachment: Dilma Rousseff in 2016. The Brazilian lower house of Parliament started an impeachment process over budgetary management questions, following a procedure nearly identical to the one used in the United States. Rousseff was removed from duties and her vice president took over while her impeachment was pending in the Brazilian Senate.

The first European head of state to be removed via impeachment was Rolandas Paksas, Lithuania’s president. The 2004 impeachment of Paskas — an erratic populist with links to Russian business figures — took place amid public concern about Russian meddling in Lithuania’s political process. But the similarities with President Trump end there: Paskas was contrite when he appeared, unsuccessfully, before Parliament to defend himself.

While the French president enjoys immunity from regular criminal prosecution while in office, they may be impeached under reforms passed in 2014, for any "breach of their duties that is clearly incompatible with the exercise of their mandate." For impeachment to begin, 10 percent of senators and 10 percent of lower house deputies must sign a resolution. To move forward two-thirds of senators and deputies need to agree to impeachment, an act which then triggers the formation of a special Republican High Court to consider the charges. The Czech Republic follows a similar model.

Italy has one of the most innovative impeachment systems. The cause of presidential impeachment needs to be high treason, and if a majority in Parliament agrees, the President then faces a jury of the Constitutional Court and 16 ordinary citizens.

Austria’s president can be removed both through a special national vote (plebiscite) and via the country’s constitutional court. Romanians have voted in two referendums since 2007 to remove their President, both of which failed.

It’s not only Western democracies that have impeachment systems. Trump’s sworn enemies in Iran also have an impeachment procedure. Abolhassan Banisadr, Iran’s first president, was successfully impeached in 1981. Iranian cabinet members may also be impeached by Parliament, and the current president, Hassan Rouhani, faced open calls for his impeachment in 2019.