ANDERSON v. DUNN
Anderson attempted to bribe a member of Congress to receive favorable treatment from the government. The House order its sergeant-at-arms (Dunn) to arrest Anderson and bring him to the House where he was reprimanded by the Speaker for his contempt of Congress. Anderson then brought an action against Dunn for assault and battery and false imprisonment, claiming that the Constitution did not vest in Congress the power to punish for contempt.
Does the Congress have the power to punish nonmembers for contempt?
Yes. Though the contempt power will not be found in the Constitution in plain terms, necessity compels it. The power is inherent in the structure and purpose of Congress. The absence of such power would lead to a total loss of power, exposing the Congress "to every indignity."