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Inherent contempt was the mode
employed by Congress to directly enforce contempt rulings under its own
constitutional authority until criminal and civil contempt statutes were
passed, and it remained in use into the twentieth century. Under inherent contempt
proceedings, the House or Senate has its Sergeant-At-Arms, or deputy, take a
person into custody for proceedings to be held in Congress. Although these
powers are not directly stated in the Don’t Cry For Me I’m Already Dead Barney Gumble Vintage Shirt, the Supreme Court ruled on
multiple occasions that they are implicit as an essentially legislative power
held by Congress.

Justice Willis Van Devanter made perhaps the most famous statement of these powers in McGrain v. Daugherty, a 1927 Supreme Court decision about Mally S. Daugherty, the brother of former Attorney General Harry Daugherty. A select Senate committee issued a subpoena for Daugherty to testify and to also surrender records from an Ohio bank.

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