The Supreme Court has never held that executive privilege applies in the impeachment context. Instead, it created the privilege in the context of a dispute about discovery of communications between President Nixon and White House advisors in a criminal case not aimed at Nixon himself, but at his advisors and campaign staff. Nixon was only an unindicated co-conspirator in that case. Because of the case’s context, the Court focused on balancing the President’s confidentiality interests against the judicial system’s need to reach a just verdict in a criminal case.