Petitioner, having testified falsely before a committee of the House of Representatives, was convicted of perjury. On trial, petitioner contested the competency of the committee, maintaining that a quorum must actually be present when the testimony is given. Evidence was offered tending to show that though there was a record quorum at the beginning of the meeting in question, this quorum was not maintained at the time petitioner testified. The trial court agreed that presence of a quorum was essential, but charged, in effect, that this requirement is satisfied by a showing of a record quorum at the outset together with the fact that the point of "no quorum" was not raised. Petitioner appealed alleging error in the instruction, and the Court of Appeals for the District of Columbia affirmed. On certiorari to the United States Supreme Court, held, reversed. Evidence of absence of a quorum in a committee of the House of Representatives is not overcome by a presumption that a quorum once established continues. Chief Justice Vinson and Justices Jackson, Reed and Burton dissented. Christoffel v. United. States, 338 U.S. 84, 69 S.Ct. 1447 (1949).
G. B. Myers S.Ed.,
CONSTITUTIONAL LAW-CONGRESSIONAL COMMITTEES-QUORUM,
Mich. L. Rev.
Available at: https://repository.law.umich.edu/mlr/vol48/iss5/12