Contempt of Congress

Last updated

Contempt of Congress [1] is the act of obstructing the work of the United States Congress or one of its committees. Historically, the bribery of a U.S. Senator or U.S. Representative was considered contempt of Congress. In modern times, contempt of Congress has generally applied to the refusal to comply with a subpoena issued by a Congressional committee or subcommittee—usually seeking to compel either testimony or the production of requested documents. [2]

Contents

History

In the late 1790s, declaring contempt of Congress was considered an "implied power" of the legislature, in the same way that the British Parliament could make findings of contempt of Parliament—early Congresses issued contempt citations against numerous individuals for a variety of actions. Some instances of contempt of Congress included citations against:

In Anderson v. Dunn (1821), [6] the Supreme Court of the United States held that Congress' power to hold someone in contempt was essential to ensure that Congress was "... not exposed to every indignity and interruption that rudeness, caprice, or even conspiracy, may mediate against it." [6] The historical interpretation that bribery of a senator or representative was considered contempt of Congress has long since been abandoned in favor of criminal statutes. In 1857, Congress enacted a law that made "contempt of Congress" a criminal offense against the United States. [7]

In the Air Mail Scandal of 1934 William MacCracken, former Assistant Secretary of Commerce for Aeronautics, was sentenced to ten days of detention for destroying evidence under subpoena. MacCracken appealed his sentence to the Supreme Court in Jurney v. MacCracken . After losing his case he surrendered to Chelsey Jurney, Senate sargeant at arms, who detained him in a room at the Willard Hotel.

While it has been said that "Congress is handcuffed in getting obstinate witnesses to comply", [8] cases have been referred to the United States Department of Justice. [9] The Office of Legal Counsel has asserted that the President of the United States is protected from contempt by executive privilege. [10] [11]

Subpoenas

The Supreme Court affirmed in Watkins v. United States that "[the] power of the Congress to conduct investigations is inherent in the legislative process" and that "[it] is unquestionably the duty of all citizens to cooperate with the Congress in its efforts to obtain the facts needed for intelligent legislative action. It is their unremitting obligation to respond to subpoenas, to respect the dignity of the Congress and its committees and to testify fully with respect to matters within the province of proper investigation." [12] Congressional rules empower all its standing committees with the authority to compel witnesses to produce testimony and documents for subjects under its jurisdiction. Committee rules may provide for the full committee to issue a subpoena, or permit subcommittees or the chairman (acting alone or with the ranking member) to issue subpoenas.

As announced in Wilkinson v. United States (1961), [13] a Congressional committee must meet three requirements for its subpoenas to be "legally sufficient." First, the committee's investigation of the broad subject area must be authorized by its chamber; second, the investigation must pursue "a valid legislative purpose" but does not need to involve legislation and does not need to specify the ultimate intent of Congress; and third, the specific inquiries must be pertinent to the subject matter area that has been authorized for investigation.

The Court held in Eastland v. United States Servicemen's Fund (1975) [14] that Congressional subpoenas are within the scope of the Speech and Debate clause which provides "an absolute bar to judicial interference" once it is determined that Members are acting within the "legitimate legislative sphere" with such compulsory process. Under that ruling, courts generally do not hear motions to quash Congressional subpoenas; even when executive branch officials refuse to comply, courts tend to rule that such matters are "political questions" unsuitable for judicial remedy. In fact, many legal rights usually associated with a judicial subpoena do not apply to a Congressional subpoena. For example, attorney-client privilege and information that is normally protected under the Trade Secrets Act do not need to be recognized. [15]

Procedures

Following the refusal of a witness to produce documents or to testify, the committee is entitled to report a resolution of contempt to its parent chamber. A Committee may also cite a person for contempt but not immediately report the resolution to the floor. In the case of subcommittees, they report the resolution of contempt to the full Committee, which then has the option of rejecting it, accepting it but not reporting it to the floor, or accepting it and reporting it to the floor of the chamber for action. On the floor of the House or the Senate, the reported resolution is considered privileged and, if the resolution of contempt is passed, the chamber has several options to enforce its mandate.

Inherent contempt

Under this process, the procedure for holding a person in contempt involves only the chamber concerned. Following a contempt citation, the person cited is arrested by the Sergeant-at-Arms for the House or Senate, brought to the floor of the chamber, held to answer charges by the presiding officer, and then subjected to punishment as the chamber may dictate (usually imprisonment for punishment, imprisonment for coercion, or release from the contempt citation). [16]

Concerned with the time-consuming nature of a contempt proceeding and the inability to extend punishment further than the session of the Congress concerned (under Supreme Court rulings), Congress created a statutory process in 1857. While Congress retains its "inherent contempt" authority and may exercise it at any time, this inherent contempt process was last used by the Senate in 1934, in a Senate investigation of airlines and the U.S. Postmaster. After a one-week trial on the Senate floor (presided over by Vice President John Nance Garner, in his capacity as Senate President), William P. MacCracken, Jr., a lawyer and former Assistant Secretary of Commerce for Aeronautics who was charged with allowing clients to remove or rip up subpoenaed documents, was found guilty and sentenced to 10 days imprisonment. [17]

MacCracken filed a petition of habeas corpus in federal courts to overturn his arrest, but after litigation, the U.S. Supreme Court ruled that Congress had acted constitutionally, and denied the petition in the case Jurney v. MacCracken . [18] [19]

Statutory proceedings

Following a contempt citation, the presiding officer of the chamber is instructed to refer the matter to the U.S. Attorney for the District of Columbia; [20] according to the law it is the duty of the U.S. Attorney to refer the matter to a grand jury for action.

The criminal offense of contempt of Congress sets the penalty at not less than one month nor more than twelve months in jail and a fine of not more than $100,000 or less than $100. [9]

Civil procedures

Senate Rules authorize the Senate to direct the Senate Legal Counsel to file a civil action against any private individual found in contempt. Upon motion by the Senate, the federal district court issues another order for a person to comply with Senate process. If the subject then refuses to comply with the Court's order, the person may be cited for contempt of court and may incur sanctions imposed by the Court. The process has been used at least six times.

Partial list of those held in contempt since 1975

PersonSubcommittee/CommitteeChamberUltimate Disposition
Rogers C.B. Morton (Republican),
Secretary of Commerce
November 11, 1975
Subcommittee of the House Committee on Interstate and Foreign Commerce
Not consideredMorton released the material to the subcommittee.
Henry Kissinger (Republican),
Secretary of State
November 15, 1975
House Select Committee on Intelligence
Not consideredCitation dismissed after "substantial compliance" with subpoena.
Joseph A. Califano, Jr. (Democrat),
Secretary of Health, Education, and Welfare
August 6, 1978
Subcommittee of the House Committee on Interstate and Foreign Commerce
Not consideredCalifano complied with the subpoena about one month after the subcommittee citation.
Charles W. Duncan, Jr. (Democrat),
Secretary of Energy
April 29, 1980
Subcommittee of the House Committee on Government Operations
Not consideredDuncan supplied the material by May 14, 1980.
James B. Edwards (Republican),
Secretary of Energy
July 23, 1981
Environment, Energy, and Natural Resources Subcommittee of the House Committee on Government Operations
Not consideredDocuments were delivered to Congress prior to full Committee consideration of the contempt citation.
James G. Watt (Republican),
Secretary of the Interior
February 9, 1982
Subcommittee of House Committee on Energy and Commerce
February 25, 1982
House Committee on Energy and Commerce
Not consideredThe White House delivered documents to the Rayburn House Office Building for review by Committee members for four hours, providing for no staff or photocopies.
Anne Gorsuch (Republican),
Administrator of the Environmental Protection Agency
December 2, 1982
Oversight Subcommittee of the House Committee on Public Works and Transportation

House Committee on Public Works and Transportation

House of RepresentativesAfter legal cases and a court dismissal of the Executive Branch's suit, the parties reached an agreement to provide documents.
Rita Lavelle (Republican),
EPA official
April 26, 1983
House Committee on Energy and Commerce
House of RepresentativesIndicted for lying to Congress; convicted; sentenced to 6 months in prison, 5 years probation thereafter, and a fine of $10,000
Jack Quinn (Democrat),
White House Counsel
May 9, 1996
House Committee on Oversight and Government Reform
Not consideredSubpoenaed documents were provided hours before the House of Representatives was set to consider the contempt citation.
David Watkins,
White House Director of Administration
Matthew Moore, White House aide
Janet Reno (Democrat),
Attorney General
August 6, 1998
House Committee on Oversight and Government Reform
Not consideredDocuments in question were revealed during the impeachment of President Clinton.
Harriet Miers (Republican),
Former White House Counsel
July 25, 2007
House Committee on the Judiciary [21]
February 14, 2008 House of Representatives [22] On March 4, 2009, Miers and former Deputy Chief of Staff to President Bush Karl Rove agreed to testify under oath before Congress about the firings of U.S. attorneys
Joshua Bolten (Republican), White House Chief of Staff
Eric Holder (Democrat), Attorney General June 20, 2012
House Committee on Oversight and Government Reform [23]
June 28, 2012 House of RepresentativesFound in contempt by a vote of 255–67 [24] [25]
Lois Lerner
Director of the IRS Exempt Organizations Division
March 11, 2014
House Committee on Oversight and Government Reform [26]
May 7, 2014 [27] House of RepresentativesFound in contempt for her role in the 2013 IRS controversy and refusal to testify. The Department of Justice has been directed by the House to appoint special counsel. (See: Finding Lois Lerner in contempt of Congress (H.Res. 574; 113th Congress))
Bryan Pagliano (Democrat)
IT director, Hillary Clinton aide
September 13, 2016
House Committee on Oversight and Government Reform [28] [29]
Not consideredHouse Committee voted, 19–15, to recommend Pagliano for a contempt resolution for failing to appear during a September 13 and 22, 2016, hearing after being subpoenaed and submitting a written Fifth Amendment plea in lieu of appearing in person. [28] [29] [30] No contempt resolution was considered by the chamber but Committee member Jason Chaffetz subsequently addressed a letter to the US Attorney General, writing as an individual member of Congress, requesting DOJ prosecution of Pagliano for misdemeanor "contumacious conduct." [31]
Backpage.com March 17, 2016
Senate Homeland Security Permanent Subcommittee on Investigations
March 17, 2016 [32] SenateFound in contempt for failing to provide documents in an investigation into human trafficking.
William P. Barr (Republican), United States Attorney General

Wilbur Ross (Republican), United States Secretary of Commerce

House Committee on Oversight and ReformJuly 17, 2019, House of Representatives [33] Refusal to Comply with Subpoenas Duly Issued by the Committee on Oversight and Reform
Donald Trump (Republican), President of the United States December 3, 2019
House Permanent Select Committee on Intelligence

December 4, 2019
House Committee on the Judiciary

December 18, 2019, House of Representatives [34] Impeached by the House of Representatives on Obstruction of Congress; acquitted by the Senate on February 5, 2020.
Chad Wolf (Republican), United States Secretary of Homeland Security September 17, 2020
House Homeland Security Committee
September 17, 2020, House of Representatives [35] Acting Homeland Secretary Chad Wolf defies subpoena and skips House hearing as he faces whistleblower allegations that he urged department officials to alter intelligence.

Other legislatures in the U.S.

Various U.S. states have made similar actions against their own legislatures' violations of state criminal laws. Sometimes, those laws can even be applied to non-sovereign legislative bodies such as county legislatures and city councils.[ citation needed ]

See also

Related Research Articles

United States Congress Legislature of the United States

The United States Congress or U.S. Congress is the bicameral legislature of the federal government of the United States and consists of the House of Representatives and the Senate. The Congress meets in the United States Capitol in Washington, D.C. Both senators and representatives are chosen through direct election, though vacancies in the Senate may be filled by a governor's appointment. Congress has 535 voting members: 100 senators and 435 representatives, the latter defined by the Reapportionment Act of 1929. In addition, the House of Representatives has six non-voting members, bringing the total membership of the Congress to 541 or fewer in the case of vacancies.

Obstruction of justice, in United States jurisdictions, is a crime consisting of obstructing prosecutors, investigators, or other government officials. Common law jurisdictions other than the United States tend to use the wider offense of perverting the course of justice.

Executive privilege is the right of the president of the United States and other members of the executive branch to maintain confidential communications under certain circumstances within the executive branch and to resist some subpoenas and other oversight by the legislative and judicial branches of government in pursuit of particular information or personnel relating to those confidential communications. The right comes into effect when revealing information would impair governmental functions. Neither executive privilege nor the oversight power of Congress is explicitly mentioned in the United States Constitution. However, the Supreme Court of the United States has ruled that executive privilege and congressional oversight each are a consequence of the doctrine of the separation of powers, derived from the supremacy of each branch in its own area of Constitutional activity.

Foreign Intelligence Surveillance Act 1978 United States federal law

The Foreign Intelligence Surveillance Act of 1978 is a United States federal law that establishes procedures for the physical and electronic surveillance and collection of "foreign intelligence information" between "foreign powers" and "agents of foreign powers" suspected of espionage or terrorism. The Act created the Foreign Intelligence Surveillance Court (FISC) to oversee requests for surveillance warrants by federal law enforcement and intelligence agencies. It has been repeatedly amended since the September 11 attacks.

Impeachment in the United States Procedure of officially accusing a civil officer

Impeachment in the United States is the process by which a legislature brings charges against a civil officer of government for crimes alleged to have been committed, analogous to the bringing of an indictment by a grand jury. Impeachment may occur at the federal level or the state level. The federal House of Representatives can impeach federal officials, including the president or vice-president, with a simple majority of the House members present or such other criteria as the House adopts in accordance with Article One, Section 2, Clause 5 of the United States Constitution. Most state legislatures can impeach state officials, including the governor, in accordance with their respective state constitution.

Congressional oversight is oversight by the United States Congress over the Executive Branch, including the numerous U.S. federal agencies. Congressional oversight includes the review, monitoring, and supervision of federal agencies, programs, activities, and policy implementation. Congress exercises this power largely through its congressional committee system. Oversight also occurs in a wide variety of congressional activities and contexts. These include authorization, appropriations, investigative, and legislative hearings by standing committees; which is specialized investigations by select committees; and reviews and studies by congressional support agencies and staff.

Reporter's privilege in the United States, is a "reporter's protection under constitutional or statutory law, from being compelled to testify about confidential information or sources." It may be described in the US as the qualified (limited) First Amendment or statutory right many jurisdictions have given to journalists in protecting their confidential sources from discovery.

A United States congressional hearing is the principal formal method by which United States congressional committees collect and analyze information in the early stages of legislative policymaking.

<i>Neri v. Senate</i>

Neri v. Senate is a controversial 9–6 ruling of the Supreme Court of the Philippines which affirmed the invocation of executive privilege by petitioner Romulo Neri, member of the Cabinet of President Gloria Macapagal-Arroyo, regarding questions asked during a Congressional inquiry on the controversial multimillion-dollar National Broadband Network (NBN) Project. The Supreme Court finally affirmed this ruling on September 4 and 23, 2008 by denying the defendant Senate Committees' first and second Motions for Reconsideration.

United States House of Representatives Lower house of the United States Congress

The United States House of Representatives is the lower house of the United States Congress, with the Senate being the upper house. Together they compose the national bicameral legislature of the United States.

Ketanji Brown Jackson American judge

Ketanji Brown Jackson is a United States District Judge of the United States District Court for the District of Columbia.

United States Senate Upper house of the United States Congress

The United States Senate is the upper chamber of the United States Congress, which, along with the United States House of Representatives—the lower chamber—constitutes the legislature of the United States. The Senate chamber is located in the north wing of the Capitol Building in Washington, D.C.

Powers of the United States Congress

Powers of the United States Congress are implemented by the United States Constitution, defined by rulings of the Supreme Court, and by its own efforts and by other factors such as history and custom. It is the chief legislative body of the United States. Some powers are explicitly defined by the Constitution and are called enumerated powers; others have been assumed to exist and are called implied powers.

Jurney v. MacCracken, 294 U.S. 125 (1935), was a case in which the Supreme Court of the United States held that Congress has an implicit power to find one in contempt of Congress. During a Senate investigation of airlines and of the U.S. Postmaster General, the attorney William P. MacCracken, Jr. allowed his clients to destroy subpoenaed documents. After a one-week trial on the Senate floor, MacCracken, a lawyer and former Assistant Secretary of Commerce for Aeronautics, was found guilty and sentenced to 10 days imprisonment. MacCracken filed a petition of habeas corpus with the federal courts to overturn his arrest, but, after litigation, the U.S. Supreme Court ruled that Congress had acted constitutionally, and denied the petition.

William P. MacCracken Jr.

William Patterson MacCracken Jr. was the first U. S. Assistant Secretary of Commerce for Aeronautics. His department was awarded the Collier Trophy of 1928 for its contribution to the "development of airways and air navigation facilities". Later he was convicted of contempt of congress in the Air Mail scandal in 1934.

Lois Lerner American attorney

Lois Gail Lerner is an American attorney and former United States federal civil service employee. Lerner became director of the Exempt Organizations Unit of the Internal Revenue Service (IRS) in 2005, and subsequently became the central figure in the 2013 IRS targeting controversy in the targeting of conservative groups, either denying them tax-exempt status outright or delaying that status until they could no longer take effective part in the 2012 election. On May 10, 2013, in a conference call with reporters, Lerner apologized that Tea Party groups and other groups had been targeted for audits of their applications for tax-exemption.[13][14][15] Both conservative and liberal groups were scrutinized. Only three groups - all branches of the Democratic group Emerge America - had tax exemptions revoked. Lerner resigned over the controversy. An investigation by the U.S. Department of Justice and Federal Bureau of Investigation, completed in 2015, found "substantial evidence of mismanagement, poor judgment and institutional inertia" but "found no evidence that any IRS official acted based on political, discriminatory, corrupt, or other inappropriate motives that would support a criminal prosecution."

Impeachment process against Richard Nixon 1970s preliminary process to remove the President of the United States

The impeachment process against Richard Nixon began in the United States House of Representatives on October 30, 1973, following the series of high-level resignations and firings widely called the "Saturday Night Massacre" during the course of the Watergate scandal. The House Committee on the Judiciary set up an impeachment inquiry staff and began investigations into possible impeachable offenses by Richard Nixon, the 37th president of the United States. The process was formally initiated on February 6, 1974, when the House granted the Judiciary Committee authority to investigate whether sufficient grounds existed to impeach Nixon of high crimes and misdemeanors under Article II, Section 4, of the United States Constitution. This investigation was undertaken one year after the United States Senate established the Select Committee on Presidential Campaign Activities to investigate the 1972 break-in at the Democratic National Committee headquarters at the Watergate office complex in Washington, D.C., and the Republican Nixon administration's attempted cover-up of its involvement; during those hearings the scope of the scandal became apparent and the existence of the Nixon White House tapes was revealed.

Efforts to impeach Donald Trump Talks and activities of attempted approaches into the possible impeachment of Donald Trump

Various people and groups assert that U.S. president Donald Trump engaged in impeachable activity both before and during his presidency, and talk of impeachment began before he took office. Grounds asserted for impeachment have included possible violations of the Foreign Emoluments Clause of the Constitution by accepting payments from foreign dignitaries; alleged collusion with Russia during the campaign for the 2016 United States presidential election; alleged obstruction of justice with respect to investigation of the collusion claim; and accusations of "Associating the Presidency with White Nationalism, Neo-Nazism and Hatred", which formed the basis of a resolution for impeachment brought on December 6, 2017.

Timeline of investigations into Donald Trump and Russia (2019) Wikimedia list article

This is a timeline of events in 2019 related to investigations into links between associates of Donald Trump and Russian officials that are suspected of being inappropriate, relating to the Russian interference in the 2016 United States elections. It follows the timeline of Russian interference in the 2016 United States elections, both before and after July 2016, until November 8, 2016, the transition, the first and second halves of 2017, the first and second halves of 2018, and followed by 2020 and 2021.

<i>In re: Don McGahn</i> American lawsuit regarding checks and balances between the Executive and Legislative Branches

In re: Don McGahn is a U.S. constitutional case lawsuit (1:19-cv-02379) filed in the United States District Court for the District of Columbia by the House Judiciary Committee to compel the testimony of former White House Counsel Donald F. McGahn, Jr. under subpoena. McGahn was put under subpoena to testify regarding his knowledge of the Russia investigation and Mueller Report and whether President Donald Trump's actions could constitute obstruction of justice. The case gained importance as the House launched impeachment proceedings against Trump regarding the Trump–Ukraine scandal.

References

  1. "Contempt of Congress". LII / Legal Information Institute. Retrieved January 21, 2020.
  2. Congressional Research Service (December 27, 2007). "Obstruction of Congress: A Brief Overview of Federal Law Relating to Interference with Congressional Activities". EveryCRSReport.com. Retrieved December 19, 2019. Obstruction of justice is the impediment of governmental activities. There are a host of federal criminal laws that prohibit obstructions of justice. The six most general outlaw obstruction of judicial proceedings (18 U.S.C. 1503), witness tampering (18 U.S.C. 1512), witness retaliation (18 U.S.C. 1513), obstruction of congressional or administrative proceedings (18 U.S.C. 1505), conspiracy to defraud the United States (18 U.S.C. 371), and contempt (a creature of statute, rule and common law). All but Section 1503 cover congressional activities.
  3. "The Case of Robert Randall and Charles Whitney, 28 December 1795–13 January 1796 (Editorial Note)".
  4. "Senate Holds Editor in Contempt".
  5. "PUNISHMENT OF WITNESSES FOR CONTEMPT".
  6. 1 2 "Anderson v. Dunn 19 U.S. 204 (1821)". justia.com. Retrieved May 18, 2017.
  7. Act of January 24, 1857, Ch. 19, sec. 1, 11 Stat. 155.
  8. Wright, Austin (May 15, 2017). "Why Flynn could easily beat his Senate subpoena". Politico . Retrieved May 17, 2017.
  9. 1 2 Congressional Research Service Report RL34097, Congress's Contempt Power and the Enforcement of Congressional Subpoenas: Law, History, Practice, and Procedure, Todd Garvey (May 12, 2017).
  10. Memorandum for the Attorney General from Theodore Olson, Re: Prosecution for the Contempt of Congress of an Executive Branch Official Who Has Asserted a Claim of Executive Privilege, 8 Op. Off. Legal Counsel 101 (1984)
  11. Memorandum for the Attorney General from Charles J. Cooper, Re: Response to Congressional Requests for Information Regarding Decisions Made Under the Independent Counsel Act, 10 Op. Off. Legal Counsel 68 (1986)
  12. Warren, Earl (1957). "WATKINS v. UNITED STATES". United States Reports. 554: 576. Retrieved August 24, 2020.
  13. "Wilkinson v. United States 365 U.S. 399 (1961)". justia.com. Retrieved May 18, 2017.
  14. "Eastland v. United States Servicemen's Fund 421 U.S. 491 (1975)". justia.com. Retrieved May 18, 2017.
  15. "Understanding Your Rights in Response to a Congressional Subpoena" (PDF). Retrieved April 24, 2019.
  16. Garvey, Todd (May 12, 2017). "Congress's Contempt Power and the Enforcement of Congressional Subpoenas: Law, History, Practice, and Procedure" (PDF). Congressional Research Service. p. 10. Retrieved April 30, 2019.
  17. "William P. Mac Cracken, Jr. Papers". ecommcode2.com. Archived from the original on April 21, 2008. Retrieved May 18, 2017.
  18. "Jurney v. MacCracken 294 U.S. 125 (1935)". justia.com. Retrieved May 18, 2017.
  19. "This is the Statement of SEN. Patrick J. Leahy, Ranking Minority Member, before the Senate Judiciary Committee". senate.gov. Archived from the original on March 18, 2017. Retrieved May 18, 2017.
  20. Eggen, Dan (April 11, 2007). "House Panel Issues First Subpoena Over Firings". The Washington Post.
  21. Stout, David (July 25, 2007). "Panel Holds Two Bush Aides in Contempt". The New York Times . Retrieved July 26, 2007.
  22. "Final Vote Results for Roll Call 60". Clerk of the United States House of Representatives. February 14, 2008. Retrieved February 14, 2008.
  23. Perez, Evan (June 20, 2012). "House Panel Votes to Hold Holder in Contempt". The Wall Street Journal . Retrieved June 20, 2012.
  24. "Final Vote Results for Roll Call 441". Clerk of the United States House of Representatives. June 28, 2012. Retrieved June 29, 2012.
  25. "Final Vote Results for Roll Call 442". Clerk of the United States House of Representatives. June 28, 2012. Retrieved June 29, 2012.
  26. "Lois Lerner's Involvement in the IRS Targeting of Tax-Exempt Organizations". house.gov. United States House Committee on Oversight and Government Reform. Archived from the original on December 25, 2018. Retrieved May 18, 2017.
  27. "House votes to hold Lerner in contempt of Congress". foxnews.com. May 7, 2014. Retrieved May 18, 2017.
  28. 1 2 Gerstein, Josh. "House panel votes to hold Clinton tech aide Bryan Pagliano in contempt". Politico . Archived from the original on October 19, 2018. Retrieved November 17, 2018.
  29. 1 2 "Examining Preservation of State Department Records". oversight.house.gov. United States House Committee on Oversight and Government Reform. Archived from the original on September 21, 2018. Retrieved May 18, 2017. In the event Mr. Pagliano fails to appear, the Committee will consider the following: Resolution and Report recommending that the House of Representatives find Bryan Pagliano in Contempt of Congress for Refusal to Comply with a Subpoena Duly Issued by the Committee on Oversight and Government Reform.
  30. "Examining Preservation of State Department Federal Records". oversight.house.gov. United States House Committee on Oversight and Government Reform. Archived from the original on September 22, 2018. Retrieved May 18, 2017.
  31. "Chaffetz Asks Justice Department to Uphold Institutional Interests of Congress" (Press release). United States House Committee on Oversight and Government Reform. February 17, 2017. Archived from the original on October 5, 2018. Retrieved November 17, 2018. Archived letter.
  32. "Homeland Security & Governmental Affairs Committee". www.hsgac.senate.gov. Retrieved May 18, 2017.
  33. "Final Vote Results for Roll Call 489, Recommending that the House of Representatives find William P. Barr, Attorney General of the United States, and Wilbur L. Ross, Jr., Secretary of Commerce, In Contempt of Congress for Refusal to Comply with Subpoenas Duly Issued by the Committee on Oversight and Reform".
  34. "Donald Trump impeached after historic vote". December 19, 2019. Retrieved December 24, 2019.
  35. "Chad Wolf defies Subpoena impeached after historic vote". December 19, 2019. Retrieved December 24, 2019.