of such
interference will be clearly seen upon consideration of its possible
consequences. Suppose the bill filed and the injunction prayed for
allowed. If the President refuse obedience, it is needless to observe
that the court is without power to enforce its process. If, on the other
hand, the President complies with the order of the court and refuses to
execute the acts of Congress, is it not clear that a collision may occur
between the executive and legislative departments of the government? May
not the House of Representatives impeach the President for such refusal?
And in that case could this court interfere, in behalf of the President,
thus endangered by compliance with its mandate, and restrain by
injunction the Senate of the United States from sitting as a court of
impeachment? Would [not?] the strange spectacle be offered to the public
world of an attempt by this court to arrest proceedings in that
court?"[469] The Court further indicated that the same principle would
apply to an application for a mandamus ordering the President to
exercise any of his powers.

THE PRESIDENT'S SUBORDINATES AND THE COURTS

But while the courts are unable to compel the President to act or to
keep him from acting, yet his acts, when performed are in proper cases
subject to judicial review and disallowance.[470] Moreover, the
subordinates through whom he acts may always be prohibited by writ of
injunction from doing a threatened illegal act which might lead to
irreparable damage,[471] or be compelled by writ of mandamus to perform
a duty definitely required by law,[472] such suits being usually brought
in the United States District Court for the District of Columbia.[473]
Also, by common law principles, a subordinate executive officer is
personally liable under the ordinary law for any act done in excess of
authority.[474] Indeed, by a recent holding, district courts of the
United States are bound to entertain suits for damages arising out of
alleged violation of plaintiff's constitutional rights, even though as
the law now stands the Court is powerless to award damages.[475] But
Congress may, in certain cases, exonerate the officer by a so-called act
of indemnity,[476] while as the law stands at present, any officer of
the United States who is charged with a crime under the laws of a State
for an act done under the authority of the United States is entitled to
have his case transferred to the national courts.[477]

Section