Motion to Impeach President Chowdhury and Vice President

Atkinson

Proposers: Margaret Peterman, LSA

External Authors: None

Non-Assembly Members in support of this question: None

Impeachment of President Alifa Chowdhury

RESOLVED, Alifa Anam Chowdhury, President of the Central Student Government, is

impeached and that the following article of impeachment be exhibited to the Central Student
Judiciary:

Articles of impeachment exhibited by the Assembly of the Central Student Government

Assembly in the name of itself and of the students of the University of Michigan, against Alifa
Anam Chowdhury, President of the Central Student Government, in maintenance and support of
its impeachment against them, denoted articles one, two, and three. Each article shall include the
charge; it shall also include the known or alleged acts of that charge, which may be amended,
added to, removed, or superseded as evidence about such acts are discovered at trial, to the
extent and if permitted by the Constitution and by law.

Impeachment of Vice President Elias Atkinson

RESOLVED, Elias Atkinson, Vice President of the Central Student Government, is impeached
and that the following article of impeachment be exhibited to the Central Student Judiciary:

Articles of impeachment exhibited by the Assembly of the Central Student Government

Assembly in the name of itself and of the students of the University of Michigan, against Elias
Atkinson, Vice President of the Central Student Government, in maintenance and support of its
impeachment against him, denoted articles four and five. Each article shall include the charge; it
shall also include the known or alleged acts of that charge, which may be amended, added to,
removed, or superseded as evidence about such acts are discovered at trial, to the extent and if
permitted by the Constitution and by law.
AND FURTHER RESOLVED, that the Central Student Judiciary be required (or urged if the
Assembly lacks the constitutional power to compel such) to hear this case within five days of this
resolution’s passage.

AND FURTHER RESOLVED, that the Speaker be empowered to select impeachment

managers for the trial(s) arising hereof.

AND FINALLY RESOLVED, that any portion of this motion and its articles be severable if
ruled unconstitutional or illegal, or if it would render an otherwise possible conviction
impossible, to the extent permitted by law.
ARTICLE 1: INCITEMENT OF VIOLENCE

The Constitution provides that the Assembly "holds the sole power of impeachment" and that
evidence is considered to determine whether "the impeached official is guilty of impeachable
conduct, as defined in the articles". It further elaborates that officials can be removed for
“delinquency, corruption, or other derelictions” (emphasis added). The Assembly finds,
declares, and defines any act of actual violence, or incitement thereof, to itself be impeachable
conduct, as well as a delinquency.

In their conduct while President of the Central Student Government — and in violation of their
oath to support the mission of the Central Student Government — Alifa Anam Chowdhury
engaged in impeachable conduct by inciting violence against the Central Student Government,1
in that:

On October 8, 2024, the Assembly of the Central Student Government met to consider two
student petitions, the Wolverines' Budget Act and the Rebuilding Education in Gaza Act. Shortly
before the meeting commenced, President Chowdhury, contacted supporters through a SHUT IT
DOWN Instagram post. This post made calls to “pack CSG”. They also willfully made
statements that, in context, encouraged — and foreseeably resulted in — lawless action at the
meeting, such as a TAHRIR Coalition email alleging that “zionist members of CSG” were
attempting to punish Palestine and remarking that they “welcome this fight, and call on you to
join us.”

Once at the meeting, President Chowdhury sat with the protestors they had assembled and spoke
with them. Thus incited by President Chowdhury, members of the crowd they had addressed,
along with President Chowdhury themself, began shouting and amassing on the floor of the
Assembly, menaced Members of the Assembly and CSG personnel, and engaged in other violent
and destructive acts.

In all this, President Chowdhury gravely endangered the security of students and the functioning
of the Central Student Government. They threatened the integrity of the democratic system,
interfered with the peaceful consideration of legislation, and imperiled a coequal branch of
Government. They thereby betrayed their trust as President, to the manifest injury of the students
of the University of Michigan.

Wherefore, Alifa Anam Chowdhury, by such conduct, has demonstrated that they will remain a
threat to student safety, democracy, and the All-Campus Constitution if allowed to remain in
office, and has acted in a manner grossly incompatible with self-governance and the rule of law.

1
All-Campus Constitution Article 1 § 5
Alifa Anam Chowdhury thus warrants impeachment and trial, removal from office, and upon
conviction, shall be disqualified to hold and enjoy any office in the Central Student Government.
ARTICLE 2: CYBERTHEFT OF CSG PROPERTY

The Constitution provides that the Assembly "holds the sole power of impeachment" and that
evidence is considered to determine whether "the impeached official is guilty of impeachable
conduct, as defined in the articles". It further elaborates that officials can be removed for
“delinquency, corruption, or other derelictions” (emphasis added). The Assembly finds,
declares, and defines a violation of any one of the three regulations below (and in general, any
violation of the Compiled Code’s prohibition on acts which are illegal or violate university
policy), the misuse of CSG’s web-based resources, as well as violating the prohibition of
defaming other members, jointly and severally, to itself be impeachable conduct, as well as
delinquencies.

In their conduct while President of the Central Student Government — and in violation of their
oath to support the mission of the Central Student Government — Alifa Anam Chowdhury
engaged in impeachable conduct by stealing the Central Student Government Instagram
account,2 in that:

On October 9, 2024, President Alifa Chowdhury changed the password to the Central Student
Government Instagram account, without authorization, in order to deny other duly authorized
users of the account access to it. They further made a post on the CSG Instagram account which
praised the actions of the protestors the previous night. In doing so, President Chowdhury did
“knowingly [cause] the transmission of a program, information, code, or command, and as a
result of such conduct, intentionally cause[d] damage without authorization, to a protected
computer” (18 U.S.C. § 1030), did “intentionally and… exceeding valid authorization…[a]ccess
or cause access to be made to a computer program, computer, computer system, or computer
network to acquire, alter, damage, delete, or destroy property or otherwise use the service of a
computer program, computer, computer system, or computer network” (MCL 752.795), and did
“attempt to gain access to university information systems or databases for which they have not
been given proper authorization” (DS-22).

The post also defamed members of CSG, falsely characterizing all members who had stood
against SHUT IT DOWN as “zionists”, despite many not being Zionists.

In a meeting of the Assembly on October 22, 2024, President Chowdhury verbally admitted to
the facts of this allegation.

Wherefore, Alifa Anam Chowdhury, by such conduct, has demonstrated that they have acted
contrary to university policy and law, and in doing so has brought disrepute upon the Central
Student Government and its members. Alifa Anam Chowdhury thus warrants impeachment and

2
Compiled Code Article IX § 2
trial, removal from office, and upon conviction, shall be disqualified to hold and enjoy any office
in the Central Student Government.
ARTICLE 3: DERELICTION OF DUTY

The Constitution provides that the Assembly "holds the sole power of impeachment" and that
evidence is considered to determine whether "the impeached official is guilty of impeachable
conduct, as defined in the articles". It further elaborates that officials can be removed for
“delinquency, corruption, or other derelictions” (emphasis added). The Assembly finds,
declares, and defines all seven alleged counts below as itself impeachable conduct, jointly and
severally, as well as derelictions.

In their conduct while President of the Central Student Government — and in violation of their
oath to support the mission of the Central Student Government — Alifa Anam Chowdhury
engaged in impeachable conduct by failing to fulfill the duties of their office,3 in that:

First, the Constitution requires that the President “prior to the end of each academic year, submit
to the Assembly and the students at large a report of the state of student government and of the
student body”. The Compiled Code further requires that “[w]ithin the first month of the Fall and
Winter semesters, the President must submit to the Assembly and to the students at large a report
of the state of the CSG and the student body.” President Alifa Chowdhury took office on April 9,
2024. In either case, President Chowdhury did not submit such a report prior to the end of the
2023–2024 academic year, nor have they more than seven months later.

Second, the Compiled Code requires that the President, like all Executive Committee members,
must complete the “Planet Blue Ambassador Training” and the “Community Leadership
Training” by “the end of the first month of their membership in the Executive Committee”. As of
November 12, 2024, over six months after the deadline, they have not completed such trainings.

Third, President Chowdhury has failed to nominate individuals for at least one position which
the Compiled Code mandates must be filled, including a Treasurer, Deputy Treasurer, and
Executive Diversity Officer.

Fourth, President Chowdhury has failed to deliver at least one report given to the Regents by
their administration thus far, despite the Compiled Code requiring as much.

Fifth, President Chowdhury has failed to complete any meaningful work whatsoever as
President of the Central Student Government. For example:
● President Chowdhury has issued only one executive order, which barred members of the
executive branch from working on April 15, 2024.
● President Chowdhury has failed to either sign or veto a majority of legislation that the
Assembly has passed.

3
Compiled Code Article IX § 3.2.1
 ● President Chowdhury has made just one valid nomination for CSG executive officials.
● President Chowdhury has spent zero dollars of the Executive Discretionary Fund, despite
having access to more than $15,000 at the time of their inauguration.
● President Chowdhury has failed to “serve [their] constituents” by failing to disperse a
single CSG dollar and by failing to execute a single CSG initiative or event.

Sixth, President Chowdhury deliberately misled members of the Assembly “about matters
related to CSG business” by promising to meet with members subject to harassment at the
October 8 meeting, and then failing to do so.

Seventh, President Chowdhury has accrued four unexcused Assembly absences (though not the
direct object of this charge, it is also worth noting that they failed to answer questions or issue a
written Executive report for these several weeks).

Wherefore, Alifa Anam Chowdhury, by such conduct above both severally and jointly, has failed
to perform duties incumbent upon them as President of the Central Student Government. Alifa
Anam Chowdhury thus warrants impeachment and trial, removal from office, and upon
conviction, shall be disqualified to hold and enjoy any office in the Central Student Government.
ARTICLE 4: INCITEMENT OF VIOLENCE

The Constitution provides that the Assembly "holds the sole power of impeachment" and that
evidence is considered to determine whether "the impeached official is guilty of impeachable
conduct, as defined in the articles". It further elaborates that officials can be removed for
“delinquency, corruption, or other derelictions” (emphasis added). The Assembly finds,
declares, and defines any act of actual violence, or incitement thereof, to be itself impeachable
conduct, as well as a delinquency.

In his conduct while Vice President of the Central Student Government — and in violation of his
oath to support the mission of the Central Student Government — Elias Atkinson engaged in
impeachable conduct by inciting violence against the Central Student Government,4 in that:

On October 8, 2024, the Assembly of the Central Student Government met to consider two
student petitions, the Wolverines' Budget Act and the Rebuilding Education in Gaza Act. Shortly
before the meeting commenced, Vice President Atkinson contacted supporters through a SHUT
IT DOWN Instagram post. This post made calls to “pack CSG”. He also willfully made
statements that, in context, encouraged — and foreseeably resulted in — lawless action at the
meeting, such as a Tahrir Coalition email alleging that “zionist members of CSG” were
attempting to punish Palestine and remarking that they “welcome this fight, and call on you to
join us.”

Thus incited by Vice President Atkinson, members of the crowd of the October 8 Assembly
meeting began shouting and amassing on the floor of the Assembly, menaced Members of the
Assembly and CSG personnel, and engaged in other violent and destructive acts.

In all this, Vice President Atkinson gravely endangered the security of students and the
functioning of the Central Student Government. He threatened the integrity of the democratic
system, interfered with the peaceful consideration of legislation, and imperiled a coequal branch
of Government. He thereby betrayed his trust as Vice President, to the manifest injury of the
students of the University of Michigan.

Wherefore, Elias Atkinson, by such conduct, has demonstrated that he will remain a threat to
student safety, democracy, and the All-Campus Constitution if allowed to remain in office, and
has acted in a manner grossly incompatible with self-governance and the rule of law. Elias
Atkinson thus warrants impeachment and trial, removal from office, and upon conviction, shall
be disqualified to hold and enjoy any office in the Central Student Government.

4
All-Campus Constitution Article 1 § 5
ARTICLE 5: DERELICTION OF DUTY

The Constitution provides that the Assembly "holds the sole power of impeachment" and that
evidence is considered to determine whether "the impeached official is guilty of impeachable
conduct, as defined in the articles". It further elaborates that officials can be removed for
“delinquency, corruption, or other derelictions” (emphasis added). The Assembly finds,
declares, and defines all five alleged counts below as itself impeachable conduct, jointly and
severally, as well as derelictions.

In his conduct while Vice President of the Central Student Government — and in violation of his
oath to support the mission of the Central Student Government — Elias Atkinson engaged in
impeachable conduct,5 in that:

First, the Constitution mandates that “the Central Student Government Vice President serves as
chair of the University Council.” The Constitution further mandates that “[t]he Council must
meet at least twice per month during the academic year.” By failing to hold any University
Council meeting at any point since taking office, Vice President Atkinson has failed to fulfill his
primary exclusive duty under the Constitution.

Second, the Compiled Code requires that the Vice President, like all Executive Committee
members, must complete the “Planet Blue Ambassador Training” and the “Community
Leadership Training” by “the end of the first month of their membership in the Executive
Committee”. As of November 12, 2024, over six months after the deadline, he has not completed
these trainings.

Third, Vice President Atkinson has to meaningfully perform any meaningful work whatsoever
as Vice President of the Central Student Government. He has yet to execute a single CSG
initiative or event.

Fourth, Vice President Atkinson deliberately misled members of the Assembly “about matters
related to CSG business” by promising to meet with members subject to harassment at the
October 8 meeting, and then failing to do so.

Fifth, Vice President Atkinson has accrued four unexcused Assembly absences (though not the
direct object of this charge, it is also worth noting that he failed to answer questions or issue a
written Executive report for these several weeks).

Wherefore, Elias Atkinson, by such conduct above both severally and jointly, has failed to
perform duties incumbent upon him as Vice President of the Central Student Government. Elias

5
Compiled Code Article IX § 3.2.1
Atkinson thus warrants impeachment and trial, removal from office, and upon conviction, shall
be disqualified to hold and enjoy any office in the Central Student Government.