expulsion actions in both the House and the Senate have generally concerned cases of perceived disloyalty to the United States Government, or the conviction of a criminal statutory offense which involved abuse of one’s official position.11 In the United States Senate, 15 Senators have been expelled, 14 during the Civil War period for disloyalty to the Union (one expulsion was later revoked by the Senate),12 and one Senator was expelled in 1797 for other disloyal conduct.13 In the House of Representatives, five Members have been expelled, including