In the 1932 case of O'Donoghue v. United States, the Supreme Court ruled that Congress could not reduce salaries or alter benefits for judges in Washington D.C.'s local courts without violating Article III of the Constitution. The plaintiff, Judge Cornelius J. O’Donoghue, argued that his salary reduction was unconstitutional as it violated the Compensation Clause which prohibits reducing a judge's pay while they are in office. The court agreed with him and held that judges serving on D.C.’s local courts were indeed “constitutional” judges under Article III and thus had lifetime tenure and protection against salary reductions during their term of service. This decision affirmed judicial independence by protecting federal judges from political pressures potentially exerted through manipulation of their compensation.

In the dissenting opinion for O'Donoghue v. United States, Justice McReynolds argued that Congress did not have the power to alter or amend the judicial system of Washington D.C., as it was established by Article III of the Constitution. He believed that this action violated separation of powers principles and undermined judicial independence. Furthermore, he contended that if Congress could change one part of the judiciary without constitutional amendment, then they could potentially do so with other parts too - a dangerous precedent to set. In his view, judges in Washington D.C were indeed officers under Article III and thus should be protected from removal except through impeachment proceedings as outlined in Section 1 of said article.