In Sinclair v. United States (1928), Harry F. Sinclair, an oil executive, was convicted of contempt of the Senate for refusing to answer questions during a congressional investigation into the Teapot Dome scandal - one of the most infamous political scandals in U.S history involving bribery and corruption over oil leases. The Supreme Court upheld his conviction with a 5-4 decision stating that Congress had not exceeded its powers by investigating him as part of its legislative function and that he could be compelled to testify before it under certain circumstances. This case affirmed Congress's power to conduct investigations as necessary for effective lawmaking and oversight functions.

In the dissenting opinion for Sinclair v. United States, Justice Oliver Wendell Holmes Jr., joined by Justice Louis Brandeis, argued that Harry F. Sinclair should not have been found in contempt of court because he was exercising his constitutional right to remain silent during a Senate investigation into the Teapot Dome scandal. They believed that the Senate overstepped its bounds and acted as a judicial body rather than a legislative one when it attempted to force Sinclair to testify against himself, which is protected under the Fifth Amendment's protection against self-incrimination. The justices also pointed out inconsistencies in how different courts had interpreted this right and called for clearer guidelines on what constitutes contempt of Congress versus legitimate use of constitutional rights.