Abstract
In a provocative recent article,1 Professors Saikrishna Prakash and Steven D. Smith argue that Congress may provide for the removal of federal judges through means other than the impeachment-and removal provisions of Articles I and II.2 Building on the work of Pro fessor Burke Shartel,3 Prakash and Smith base their claim of im peachment nonexclusivity on the provisions of Article III.4 Prakash and Smith suggest that, in addition to congressional im peachment and removal for treason, bribery, or other high crimes and misdemeanors, judges may be removed following a judicial determi nation that they have violated the good behavior provisions of their office under Article III. Although they do not dwell on the point,
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