In the 1934 case of Jurney v. MacCracken, the United States Supreme Court upheld Congress's power to hold individuals in contempt for obstructing its proceedings. The case arose when William P. MacCracken Jr., a former Assistant Secretary of Commerce for Aeronautics, allowed documents subpoenaed by a Senate committee investigating air mail contracts to be removed and destroyed. He was subsequently held in contempt by the Senate and arrested on their order. In his defense, MacCracken argued that since he had not been directly disruptive during an actual session of Congress, they did not have authority to hold him in contempt or arrest him outside their chambers. The Supreme Court disagreed with this argument and ruled against MacCracken unanimously (8-0). They stated that Congressional investigations are considered legislative processes; therefore obstruction of these investigations is equivalent to obstructing sessions of Congress itself which gives them grounds for holding someone in contempt under their inherent powers as a legislative body.

In the dissenting opinion for Jurney v. MacCracken, Justice McReynolds argued that the Senate overstepped its constitutional authority by imprisoning William P. MacCracken Jr., a private citizen, for destroying subpoenaed documents. He contended that only courts have the power to punish contempt of court and not legislative bodies like Congress or Senate. The Constitution does not explicitly grant such powers to these bodies nor can it be inferred from their functions or duties as lawmakers. Furthermore, he emphasized that this case was about personal liberty - an individual's right against unlawful detention without due process of law which is protected under Fifth Amendment rights in U.S constitution. Therefore, according to him, Mr.MacCracken should have been tried in a regular court with all legal protections rather than being summarily punished by Senate.