MCGRAIN v. DAUGHERTY
This case was a challenge to Daugherty's contempt conviction. He failed to appear before a Senate committee investigating the failure of Daugherty's brother (Harry Daugherty, the former Attorney General)to prosecute wrongdoers in the Teapot Dome scandal.
Was the Senate committee out-of-bounds in issuing its contempt order since the purpose of the investigation had nothing to do with the committee's legislative purpose?
The Court upheld Daugherty's contempt conviction, establishing a presumption that congressional investigations have a legislative purpose. This presumption was not overcome by showing that the committee also had another purpose, such as exposure of wrongdoing. This presumption would later restrict the Court's hand in clear cases of congressional overreaching while investigating communists after World War II.