McGrain v. Daugherty

The case of McGrain v. Daugherty dealt with Congress's power to investigate. In this instance, the legislative body was investigating into a far-reaching scandal that came to be known as Teapot Dome. Since 1909, the U.S. government had set aside three tracts of oil-bearing land--Elk Hills and Buena Vista in California and Teapot Dome in Wyoming--for use by the U.S. Navy in case of an emergency oil shortage. When President Warren G. Harding took office in 1920, he transferred the reserves from the custody of the U.S. Navy to his close friend and newly appointed Secretary of the Interior, Albert B. Fall. Within two years, and without congressional approval, Fall leased the Teapot Dome Reserve to a private oil company without competitive bidding. These activities were later brought to light by the press.

In October of 1923, an investigation revealed that Fall had received cash and cattle in exchange for the lease on Teapot Dome and other oil reserves. Fall was tried and initially acquitted for conspiracy to defraud the government. In 1929, he was convicted of bribery, fined $100,000, and sentenced to a year in jail. For a time, Fall had enjoyed the protection of powerful friends in the government, including Attorney General Harry M. Daugherty. However, widespread distrust of the Department of Justice and of Daugherty (who resigned in 1924), as well as the pressures brought to bear by extensive press coverage of the scandal, caused Congress to initiate an investigation of Daugherty's failure to prosecute the malefactors in the scandal.