command of the Armed Forces is delegated to the Department of Defense and is normally exercised through the secretary of defense. The chairman of the Joint Chiefs of Staff and the Combatant Commands assist with the operation as outlined in the presidentially approved Unified Command Plan (UCP). Juridical powers and privileges The president has the power to nominate federal judges, including members of the United States courts of appeals and the Supreme Court of the United States. However, these nominations require Senate confirmation before they may take office. Securing Senate approval can provide a major obstacle for presidents who wish to orient the federal judiciary toward a particular ideological stance. When nominating judges to U.S. district courts, presidents often respect the long-standing tradition of senatorial courtesy. Presidents may also grant pardons and reprieves. Gerald Ford pardoned Richard Nixon a month after taking office. Presidents often grant pardons shortly before leaving office, like when Bill Clinton pardoned Patty Hearst on his last day in office; this is often controversial. Two doctrines concerning executive power have developed that enable the president to exercise executive power with a degree of autonomy. The first is executive privilege, which allows the president to withhold from disclosure any communications made directly to the president in the performance of executive duties. George Washington first claimed the privilege when Congress requested to see Chief Justice John Jay's notes from an unpopular treaty negotiation with Great Britain. While not enshrined in the Constitution or any other law, Washington's action created the precedent for the privilege. When Nixon tried to use executive privilege as a reason for not turning over subpoenaed evidence to Congress during the Watergate scandal, the Supreme Court ruled in United States v. Nixon, , that executive privilege did not apply in cases where a president was attempting to avoid criminal prosecution. When Bill Clinton attempted to use executive privilege regarding the Lewinsky scandal, the Supreme Court ruled in Clinton v. Jones, , that the privilege also could not be used in civil suits. These cases established the legal precedent that executive privilege is valid, although the exact extent of the privilege has yet to be clearly defined. Additionally, federal courts have allowed this privilege to radiate outward and protect other executive branch employees, but have weakened that protection for those executive branch communications that do not involve the president. The state secrets privilege allows the president