Does the phrase “High … Misdemeanors” mean breach of fiduciary duty?

According to Impeachment: The Constitution’s Fiduciary Meaning of “High . . . Misdemeanors”, Federalist Society Review, the answer is “yes.”  From the article’s conclusion:

We best capture the meaning of the phrase “high . . . Misdemeanors” when we think of it as referring to breaches of fiduciary duty. High misdemeanors are not limited to commission of crimes, but they do not include mere political differences. While violations of the criminal law provide grounds for impeachment, high misdemeanors encompass breaches of the duties of loyalty, good faith, and care, and of the obligations to account and to follow instructions (including the law and Constitution) when administering one’s office.

— Joe

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