# Anderson v. Dunn **Status: stub — expand.** **19 U.S. (6 Wheat.) 204 (1821).** The case that established that each house of Congress possesses an **inherent** power to punish contempts of its authority — to order its Sergeant at Arms to arrest a person, bring him to the bar of the chamber, and hold him — without any statute conferring that power and without a court. The power is implied rather than enumerated: a legislature that could not compel the attendance of witnesses or punish defiance of its process would be, in the Court's reasoning, exposed to "every indignity and interruption that rudeness, caprice, or even conspiracy, may mediate against it." The holding came with the limit that still defines the route: the punishment is **the least possible power adequate to the end proposed**, and imprisonment may not extend beyond the end of the current session of Congress. That ceiling is why inherent contempt is a coercive instrument and not a punitive one, and it is part of why the route has not been used since 1935. ## See also - [[Congressional Subpoena Enforcement Flow]] · [[McGrain v. Daugherty]] · [[Jurney v. MacCracken]] · [[Congressional Oversight]] · [[Sergeant at Arms]]