Petitioner was attorney for certain air lines and during the course of the "Air Mail" contracts investigation in the Senate in 1934 was ordered to produce certain correspondence. He delayed, claiming an attorney's privileges, and either he or his partner allowed clients to remove certain of the papers asked for from his files. Some of the papers were later returned by the clients, and others were destroyed. Petitioner was committed for contempt of the Senate and brought habeas corpus proceedings. Held, (1) neither the fact that an obstruction of legislative process has been removed or that its removal has become impossible, (2) nor the fact that the same act was also a misdemeanor punishable in the courts, will prevent commitment for contempt; (3) whether under the facts petitioner was actually guilty or had purged himself of contempt, is for the Senate, not the courts, to determine. Jurney v. MacCracken, (U.S. 1935) 55 Sup. Ct. 375; reversing MacCracken v. Jurney, (App. D. C. 1934) 72 F. (2d) 560.
CONSTITUTIONAL LAW - POWER OF CONGRESS TO PUNISH FOR CONTEMPT - POWER TO PUNISH FOR COMPLETED ACTS,
Mich. L. Rev.
Available at: https://repository.law.umich.edu/mlr/vol33/iss6/13