In the United States v. Daugherty case of 1925, Harry M. Daugherty, former Attorney General of the United States, was indicted on charges related to conspiracy and defrauding the government in connection with his alleged misuse of public funds during President Harding's administration. The Supreme Court ruled that a Senate committee did not have authority to compel testimony from private citizens regarding potential criminal conduct outside its legislative purview. It held that while Congress has broad powers to investigate matters relating to legislation or oversight, it does not possess general power for law enforcement; such power is vested in executive and judicial branches instead.

In the dissenting opinion for United States v. Daugherty, Justice McReynolds argued that the majority's decision to dismiss the case was premature and inappropriate. He contended that it was not within their jurisdiction to decide whether or not a Senate committee had exceeded its powers in investigating alleged corruption in the Department of Justice. Instead, he believed this question should be left up to Congress itself. Furthermore, he disagreed with the majority's interpretation of legislative power under Article I of Constitution; according to him, such an expansive view could potentially lead to abuses by Congressional committees at expense of individual rights and separation of powers principles. Finally, he expressed concern about potential negative consequences on future investigations into governmental misconduct if courts were allowed intervene prematurely based on defendants' claims about improper motives or methods used by investigators.