The power of inquiry, with process to enforce it, is an essential and appropriate part of the legislative function.
In December, 1859, the Senate appointed a committee to inquire into the facts concerning the invasion and seizure of the armory and arsenal at Harper's Ferry and to report facts and recommend legislation. The committee had the power to send for persons and papers. In February 1860, a resolution was adopted directing the Deputy Sergeant-at-Arms of the Senate to take into his custody Thaddeus Hyatt, and to bring him before the bar of the Senate to answer for contempt of its authority. Pursuant to this resolution, Hyatt was brought before the bar, and a resolution was adopted directing him to be committed by the Sergeant-at-Arms to the common jail of the District of Columbia, to be kept in close custody until he should signify his willingness to answer the questions propounded by the Senate. Thereafter, Hyatt filed for a petition for a writ of habeas corpus, which the United States District Court for the Southern District of Ohio granted. The Deputy appealed.
Did the trial court err in granting Hyatt’s petition for a writ of habeas corpus?
The Court ruled that the district court erred in discharging the witness from custody under the attachment. The Court held that the investigation was ordered for a legitimate object, that the witness wrongfully refused to appear and testify before the committee and was lawfully attached, and that the Senate was entitled to have the witness give testimony pertinent to the inquiry, either at its bar or before the committee. In so doing, the Court found that although the Senate was not invested with a "general" power to inquire into private affairs and compel disclosures, it did possess such auxiliary powers as were necessary and proper to make its express powers effective. The power to legislate carried with it by necessary implication ample authority to obtain information needed in the rightful exercise of that power. The investigation of a public officer or department was presumed legislative in purpose and, therefore, valid.