[577][578] Investigators decided they could not "apply an approach that could potentially result in a judgment that the President committed crimes" as an Office of Legal Counsel opinion stated that a sitting president could not be indicted,[579] and investigators would not accuse him of a crime when he cannot clear his name in court.[580] The report concluded that Congress, having the authority to take action against a president for wrongdoing, "may apply the obstruction laws".[579] The House of Representatives subsequently launched an impeachment inquiry following the Trump–Ukraine scandal, but did not pursue an article of impeachment related to the Mueller investigation.[581][582]
Several Trump associates pleaded guilty or were convicted in connection with Mueller's investigation and related cases. Manafort, convicted on eight felony counts,[583] deputy campaign manager Rick Gates,[584] foreign policy advisor Papadopoulos,[585] and Flynn.[586][587] Cohen pleaded guilty to lying to Congress about Trump's 2016 attempts to reach a deal with Russia to build a Trump Tower in Moscow. Cohen said he had made the false statements on behalf of Trump, who was identified as "Individual-1" in the court documents.