In the 1967 case of Will v. United States, U.S. District Judge Hubert L. Will challenged his conviction for contempt of court after he refused to comply with a subpoena issued by a grand jury investigating corruption in Illinois state government. The Supreme Court ruled against Judge Will, upholding his conviction and affirming that federal judges are not immune from prosecution for criminal conduct committed while in office. The decision clarified that judicial immunity does not extend to actions taken outside the scope of judicial duties or those involving personal misconduct unrelated to official functions. It also confirmed that federal judges could be held accountable under criminal law if they engage in illegal activities, even when such activities involve their use of power as public officials. This ruling set an important precedent regarding checks and balances within the judiciary system itself, emphasizing accountability among all branches of government regardless of position or authority level.

In the dissenting opinion for Will v. United States, Justice Harlan argued that Congress did not intend to reduce judges' salaries in real terms when it suspended annual cost-of-living adjustments. He believed that the majority misinterpreted Congressional intent and failed to recognize a distinction between a salary increase and an adjustment meant to counteract inflation's effects on purchasing power. Furthermore, he contended that this decision undermined judicial independence by allowing Congress to effectively decrease judges' compensation indirectly through inflationary erosion of their nominal pay rates. This, according to him, was contrary to the Constitution’s Compensation Clause which protects against diminution of judge’s remuneration during their time in office.