In the 1948 case of Christoffel v. United States, the Supreme Court ruled in favor of William P. Christoffel, who had been convicted for perjury before a congressional committee. The court held that since there was no quorum present when he allegedly lied under oath (only six out of nine members were present), his conviction could not stand as it violated Article I, Section 5 of the Constitution which states that a majority constitutes a quorum to do business in each house of Congress. Therefore, any testimony given without such quorum cannot be considered "competent" and thus cannot form basis for perjury charges. This ruling emphasized the importance and necessity for maintaining constitutional requirements during official proceedings.

In the dissenting opinion for CHRISTOFFEL v. UNITED STATES, Justice Murphy argued that Christoffel's conviction was based on an incorrect interpretation of the law and should be overturned. He contended that a quorum in Congress is not simply defined by the number of members present but also requires their active participation in proceedings. In this case, he believed there was no evidence to suggest a quorum had been actively participating at the time Christoffel allegedly lied under oath before a congressional committee; therefore, his perjury charge should be dismissed. Furthermore, Justice Murphy criticized the majority for ignoring key aspects of legislative history and precedent which supported this view. He warned against allowing convictions based on such loose interpretations as it could potentially undermine citizens' constitutional rights and protections.