The Oyez Project: 1924 Term Decisions

Ex parte Grossman (No. 24)

Did the president have the constitutional authority to commute a sentence for criminal contempt of court?

In a unanimous decision, the Court found that a presidential pardon for a criminal contempt of court sentence was within the powers of the executive. There is nothing in the words "offenses against the United States" that excludes criminal contempts in the Constitution. Actions that violate the dignity or authority of the federal courts violate the law of the United States, making these contempts offenses against the United States. The president's pardon authority includes such offenses. Without destroying the deterrent effect of judicial punishment, the president's powers are to act as checks against undue prejudice or needless severity in such sentencing by the judicial branch.

McGrain v. Daugherty (No. 28)

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.

Myers v. United States (No. 2)

Did the Act unconstitutionally restrict the President's power to remove appointed officials?

Yes. After tracing legislative debate of the First Congress in 1789 which dealt with the interpretation of the President's appointment power, Chief Justice Taft concluded that the power to remove appointed officers is vested in the President alone. According to Taft, to deny the President that power would not allow him to "discharge his own constitutional duty of seeing that the laws be faithfully executed."

Pierce v. Society of Sisters (No. 583)

Did the Act violate the liberty of parents to direct the education of their children?

Yes. The unanimous Court held that "the fundamental liberty upon which all governments in this Union repose excludes any general power of the State to standardize its children by forcing them to accept instruction from public teachers only."