McGrain v. Daugherty 1927

Author:Daniel Brannen, Richard Hanes, Elizabeth Shaw

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Appellant: John J. McGrain

Appellee: Mally S. Daugherty

Appellant's Claim: That the U.S. Senate had not exceeded its authority in requiring a private citizen to testify before its investigation committee concerning the Teapot Dome scandal.

Chief Lawyer for Appellant: George W. Wickersham

Chief Lawyer for Appellee: Arthur I. Vorys, John P. Phillips

Justices for the Court: Louis D. Brandeis, Pierce Butler, Oliver Wendell Holmes, James C. McReynolds, Edward T. Sanford, George Sutherland, Chief Justice William H. Taft, Willis Van Devanter

Justices Dissenting: None (Harlan Fiske Stone did not participate)

Date of Decision: January 17, 1927

Decision: Ruled in favor of McGrain by finding the Senate had an implied constitutional authority to carry out a congressional investigation of Daugherty.

Significance: The ruling clearly established Congress' power to conduct investigations even without stating a specific legislative purpose. The decision dramatically expanded Congress' ability to investigate the lives and activities of citizens. This power has been regularly exercised by Congress ever since. The decision was also considered the first to uphold the power of Congress or the courts to override on certain occasions claims of executive privilege if a president, his cabinet members, or presidential aides were called to testify.

Page 881

In 1927 the U.S. Supreme Court issued a landmark ruling, McGrain v. Daugherty. The ruling firmly established Congress' power to conduct investigations, even without any specifically stated legislative (law making) purpose and to gather information by requiring private citizens to give testimony. The ruling arose out of a situation referred to as Teapot Dome. Teapot Dome was one of the most infamous (bad reputation) government scandals in U.S. history and became a symbol of corruption in the U.S. government.

The Teapot Dome Scandal

In 1909, President William Howard Taft (1909–1913) set aside three tracts of oil-bearing land, Elk Hills and Buena Vista in California and Teapot Dome in Wyoming, for use by the U.S. Navy in case of an emergency oil shortage. In 1921, President Warren G. Harding (1921–1923) took office and within a year transferred control of the three naval oil reserves to his good friend and newly-appointed Secretary of the Interior, Albert B. Fall. With neither congressional approval nor competitive bidding, in 1922 Fall leased the reserves at Elk Hills and Teapot Dome to private oil companies of Edward L. Doheny and...

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