# Jurney v. MacCracken **Status: stub — expand.** **294 U.S. 125 (1935).** William P. MacCracken, an aviation lawyer and former Assistant Secretary of Commerce, allowed clients to remove and destroy papers covered by a Senate subpoena during the air-mail contracts investigation. The Senate ordered its Sergeant at Arms, Chesley Jurney, to arrest him. MacCracken sought habeas corpus; the Supreme Court denied relief. The holding matters because it answers the objection that inherent contempt is purely coercive: the Court held that the Senate may **punish a past and completed contempt** even where compliance is no longer possible, so the power is not extinguished when the documents are already gone. Its significance in 2026 is chronological rather than doctrinal. **This is the last occasion on which either chamber actually ran an inherent-contempt proceeding to a detention.** Everything since has gone through the criminal statute or the courts, which is why the route survives on paper and nowhere else. ## See also - [[Congressional Subpoena Enforcement Flow]] · [[Anderson v. Dunn]] · [[McGrain v. Daugherty]] · [[Sergeant at Arms]]