Contempt of Congress

Contempt of Congress{{Cite web|url=https://www.law.cornell.edu/wex/contempt_of_congress|title=Contempt of Congress|website=LII / Legal Information Institute|language=en|access-date=2020-01-21|archive-date=August 3, 2013|archive-url=https://web.archive.org/web/20130803060749/http://www.law.cornell.edu/wex/contempt_of_Congress|url-status=live}} is the misdemeanor 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.{{cite web |title=Obstruction of Congress: A Brief Overview of Federal Law Relating to Interference with Congressional Activities |url=https://www.everycrsreport.com/reports/RL34304.html |publisher=EveryCRSReport.com |author=Congressional Research Service |access-date=19 December 2019 |date=27 December 2007 |quote=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. |archive-date=December 19, 2019 |archive-url=https://web.archive.org/web/20191219145643/https://www.everycrsreport.com/reports/RL34304.html |url-status=live }}

History

In the late 1790s, declaring contempt of Congress was considered an "implied power" of the legislature, in a similar manner as 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:

Robert Randal, for an attempt to bribe Representative William Smith of South Carolina in 1795.{{Cite web|url=http://founders.archives.gov/documents/Madison/01-16-02-0092|title=Founders Online: The Case of Robert Randall and Charles Whitney, 28 December 17 …|website=founders.archives.gov}}
William Duane, a newspaper editor who refused to answer Senate questions in 1800.{{Cite web|url=https://www.senate.gov/artandhistory/history/minute/Senate_Holds_Editor_in_Contempt.htm|title=U.S. Senate: Senate Holds Editor in Contempt|website=www.senate.gov}}
Nathaniel Rounsavell, another newspaper editor, for releasing sensitive information to the press in 1812.{{Cite web|url=https://www.govinfo.gov/content/pkg/GPO-HPREC-HINDS-V3/html/GPO-HPREC-HINDS-V3-2.htm|title=Hinds' Precedents, Volume 3 – Chapter 53 – Punishment of Witnesses for Contempt|website=www.govinfo.gov}}

In Anderson v. Dunn (1821),{{cite web|url=http://supreme.justia.com/us/19/204/case.html|title=Anderson v. Dunn 19 U.S. 204 (1821)|website=justia.com|access-date=May 18, 2017}} the Supreme Court of the United States held that Congress's 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."

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.Act of January 24, 1857, Ch. 19, sec. 1, 11 Stat. 155.

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 Chesley Jurney, Senate sergeant 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",{{cite news|last1=Wright|first1=Austin|title=Why Flynn could easily beat his Senate subpoena|url=http://www.politico.com/story/2017/05/15/flynn-senate-subpoena-russia-trump-238404|access-date=17 May 2017|work=Politico|date=15 May 2017}} cases have been referred to the United States Department of Justice.Congressional Research Service Report RL34097, [https://fas.org/sgp/crs/misc/RL34097.pdf Congress's Contempt Power and the Enforcement of Congressional Subpoenas: Law, History, Practice, and Procedure], Todd Garvey (May 12, 2017). The Office of Legal Counsel has asserted that the President of the United States is protected from contempt by executive privilege.Memorandum for the Attorney General from Theodore Olson, Re: [https://www.justice.gov/sites/default/files/olc/opinions/1984/05/31/op-olc-v008-p0101_0.pdf Prosecution for the Contempt of Congress of an Executive Branch Official Who Has Asserted a Claim of Executive Privilege] {{Webarchive|url=https://web.archive.org/web/20170225034358/https://www.justice.gov/sites/default/files/olc/opinions/1984/05/31/op-olc-v008-p0101_0.pdf |date=February 25, 2017 }}, 8 Op. Off. Legal Counsel 101 (1984)Memorandum for the Attorney General from Charles J. Cooper, Re: [https://www.justice.gov/sites/default/files/olc/opinions/1986/04/31/op-olc-v010-p0068_0.pdf Response to Congressional Requests for Information Regarding Decisions Made Under the Independent Counsel Act] {{Webarchive|url=https://web.archive.org/web/20191208071159/https://www.justice.gov/sites/default/files/olc/opinions/1986/04/31/op-olc-v010-p0068_0.pdf |date=December 8, 2019 }}, 10 Op. Off. Legal Counsel 68 (1986)

In March 2024, it was reported that Peter Navarro would be the first former White House official to be imprisoned for a contempt of Congress criminal conviction.{{cite news|url=https://www.politico.com/news/2024/03/19/peter-navarro-prison-miami-00147790|title='I'm pissed': Ex-Trump aide Peter Navarro blasts justice system before heading to federal prison|first1=Kimberly|last1=Leonard|first2=Kyle|last2=Cheney|publisher=Politico|date=March 19, 2024|accessdate=July 1, 2024}} Steve Bannon would then follow in July 2024.{{cite news|url=https://www.cnn.com/2024/07/01/politics/steve-bannon-report-to-prison/index.html|title=Steve Bannon begins serving 4-month sentence in federal prison for defying congressional subpoena|first1=Sara|last1=Murray|first2=Katelyn|last2=Polantz|first3=Devan|last3=Cole|publisher=CNN|date=July 1, 2024|accessdate=July 1, 2024}} Both Navarro and Bannon's contempt of Congress convictions and prison sentences were connected with their refusals to comply with subpoenas which required them testify before the now-defunct House Select Committee that investigated January 6, 2021.

Subpoenas

The Supreme Court affirmed in Watkins v. United States (1957) 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."{{cite journal |last1=Warren |first1=Earl |title=WATKINS v. UNITED STATES |journal=United States Reports |date=1957 |volume=554 |page=576 |url=https://www.law.cornell.edu/supremecourt/text/354/178 |access-date=August 24, 2020}} 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),{{cite web|url=http://supreme.justia.com/us/365/399/case.html|title=Wilkinson v. United States 365 U.S. 399 (1961)|website=justia.com|access-date=May 18, 2017}} 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){{cite web|url=http://supreme.justia.com/us/421/491/case.html|title=Eastland v. United States Servicemen's Fund 421 U.S. 491 (1975)|website=justia.com|access-date=May 18, 2017}} that congressional subpoenas are within the scope of the Speech or 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.{{cite web|url=https://www.mayerbrown.com/files/Publication/ec1203b2-a787-44ac-8344-5d5fab374ffa/Presentation/PublicationAttachment/11509b8b-df81-4db6-9e89-1d1b16c20856/White-Paper-Congressional-Subpoena.pdf |title=Understanding Your Rights in Response to a Congressional Subpoena |author= |access-date=24 April 2019}}

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 of 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).{{cite web |last=Garvey |first=Todd |title=Congress's Contempt Power and the Enforcement of Congressional Subpoenas: Law, History, Practice, and Procedure |publisher=Congressional Research Service |pages=10|date=12 May 2017 |url=https://fas.org/sgp/crs/misc/RL34097.pdf |access-date=30 April 2019 }}

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 President of the Senate), 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.{{cite web|url=http://www.ecommcode2.com/hoover/research/historicalmaterials/other/maccrack.htm|title=William P. Mac Cracken Jr. Papers|website=ecommcode2.com|access-date=May 18, 2017|url-status=usurped|archive-url=https://web.archive.org/web/20080421135250/http://www.ecommcode2.com/hoover/research/historicalmaterials/other/maccrack.htm|archive-date=April 21, 2008|df=mdy-all}}

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.{{cite web|url=http://supreme.justia.com/us/294/125/case.html|title=Jurney v. MacCracken 294 U.S. 125 (1935)|website=justia.com|access-date=May 18, 2017|archive-date=August 11, 2011|archive-url=https://web.archive.org/web/20110811095052/http://supreme.justia.com/us/294/125/case.html|url-status=live}}{{cite web|url=http://judiciary.senate.gov/oldsite/5182000_pjl8.htm|title=This is the Statement of SEN. Patrick J. Leahy, Ranking Minority Member, before the Senate Judiciary Committee|website=senate.gov|access-date=May 18, 2017|archive-url=https://web.archive.org/web/20170318043216/https://www.judiciary.senate.gov/oldsite/5182000_pjl8.htm|archive-date=March 18, 2017|url-status=dead}}

The last attempt by the House of Representatives to use this inherent contempt process was on July 11, 2024, when they voted on a resolution that could have held Attorney General Merrick Garland in inherent contempt of Congress. The resolution would have imposed a fine of $10,000 per day on Garland for defying a congressional subpoena until he handed over audio of former special counsel Robert Hur’s interview with President Joe Biden.{{cite web |last1=Carney |first1=Jordain |title=House GOP fails to pass effort to fine Garland $10,000 per day |url=https://www.politico.com/live-updates/2024/07/11/congress/house-gop-flops-on-inherent-contempt-00167562 |publisher=Politico |access-date=23 September 2024 |date=11 July 2024}} This attempt fell short in a 204 to 210 vote by the House of Representatives and Garland was not found in inherent contempt, with four Republicans voting with all Democrats to oppose the measure.{{cite web |last1=Hubbard |first1=Kaia |title=Republican effort to hold Attorney General Merrick Garland in inherent contempt of Congress falls short |url=https://www.cbsnews.com/news/merrick-garland-inherent-contempt-of-congress/ |publisher=CBS News |access-date=23 September 2024 |date=11 July 2024}}

= 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;{{cite news| url=https://www.washingtonpost.com/wp-dyn/content/article/2007/04/10/AR2007041000839.html | newspaper=The Washington Post | first=Dan | last=Eggen | title=House Panel Issues First Subpoena Over Firings | date=April 11, 2007}} 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 is a misdemeanor, punishable by a fine of not more than $100,000 nor less than $100 and imprisonment in a common jail for not less than one month nor more than twelve months.

= 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 contempt resolutions since 1975

class="wikitable sortable" style="font-size: 90%;"
Person ! Subcommittee/Committee ! Chamber ! Ultimate Disposition
Rogers C.B. Morton, Secretary of Commerce \| November 11, 1975 Subcommittee of the House Committee on Interstate and Foreign Commerce \| Not considered \| Morton released the material to the subcommittee.
Henry Kissinger, Secretary of State \| November 15, 1975 House Select Committee on Intelligence \| Not considered \| Citation dismissed after "substantial compliance" with subpoena.
Joseph A. Califano Jr., Secretary of Health, Education, and Welfare \| August 6, 1978 Subcommittee of the House Committee on Interstate and Foreign Commerce \| Not considered \| Califano complied with the subpoena about one month after the subcommittee citation.
Charles W. Duncan Jr., Secretary of Energy \| April 29, 1980 Subcommittee of the House Committee on Government Operations \| Not considered \| Duncan supplied the material by May 14, 1980.
James B. Edwards, Secretary of Energy \| July 23, 1981 Environment, Energy, and Natural Resources Subcommittee of the House Committee on Government Operations \| Not considered \| Documents were delivered to Congress prior to full Committee consideration of the contempt citation.
James G. Watt, 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 considered \| The 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, 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 Representatives \| U.S. Attorney Stanley S. Harris never presented the case to a Grand Jury as required by law.{{Cite news\|last1=Maitland\|first1=Leslie\|date=1983-03-14\|title=U.S. ATTORNEY SAID TO ACT ON HIS OWN IN NOT PRESSING BURFORD CASE\|language=en-US\|newspaper=The New York Times\|url=https://www.nytimes.com/1983/03/14/us/us-attorney-said-to-act-on-his-own-in-not-pressing-burford-case.html\|access-date=2021-05-09\|issn=0362-4331}} After legal cases and a court dismissal of the Executive Branch's suit, the parties reached an agreement to provide documents and withdrew contempt citation.
Rita Lavelle, EPA official \| April 26, 1983 House Committee on Energy and Commerce \| House of Representatives \| Indicted for contempt of Congress, but acquitted in trial;{{cite web\|url=https://www.washingtonpost.com/history/2021/11/13/steve-bannon-contempt-congress-rita-lavelle/\|title=Decades before Steve Bannon was charged with contempt of Congress, Rita Lavelle was tried\|author=Timothy Bella\|date=November 13, 2021\|website=washingtonpost.com}} Later convicted for lying to Congress and sentenced to 6 months in prison, 5 years probation thereafter, and a fine of $10,000.{{cite news\|last=Shabecoff\|first=Philip\|date=January 10, 1984\|title=Rita Lavelle gets 6-month term and is fined $10,000 for perjury\|newspaper=The New York Times\|page=A1\|url=https://www.nytimes.com/1984/01/10/us/rita-lavelle-gets-6-month-term-and-is-fined-10000-for-perjury.html\|access-date=July 1, 2024}}{{cite news \| publisher = content.time.com \| date = December 12, 1983 \| title = Costly Lies: Rita Lavelle is convicted of perjury \| url = http://content.time.com/time/magazine/article/0,9171,921404,00.html}}
Jack Quinn, White House Counsel \| rowspan="2" \| May 9, 1996 House Committee on Oversight and Government Reform \| rowspan="2" \| Not considered \| rowspan="2" \| Subpoenaed 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, Attorney General \| August 6, 1998 House Committee on Oversight and Government Reform \| Not considered \| The majority of documents in question were released following the conclusion of the Department of Justice investigation into campaign finance violations of 1996. However, an additional memo was withheld and later claimed as privileged by the George W. Bush administration.{{Cite news\|last=Marquis\|first=Christopher\|date=2000-05-19\|title=F.B.I. Memo Details Freeh Warning to Reno\|language=en-US\|newspaper=The New York Times\|url=https://www.nytimes.com/2000/05/19/us/fbi-memo-details-freeh-warning-to-reno.html\|access-date=2021-05-09\|issn=0362-4331}}
Harriet Miers, Former White House Counsel \| rowspan="2" \| July 25, 2007 House Committee on the Judiciary{{cite news \|last=Stout \|first=David \|title=Panel Holds Two Bush Aides in Contempt \|work=The New York Times \|date=July 25, 2007 \|url=https://www.nytimes.com/2007/07/25/washington/25cnd-contempt.html \|access-date=July 26, 2007 \|archive-date=April 17, 2014 \|archive-url=https://web.archive.org/web/20140417111153/http://www.nytimes.com/2007/07/25/washington/25cnd-contempt.html \|url-status=live }} \| rowspan="2" \| February 14, 2008 House of Representatives{{cite web \|title=Final Vote Results for Roll Call 60 \|publisher=Clerk of the United States House of Representatives \|date=February 14, 2008 \|url=http://clerk.house.gov/cgi-bin/vote.asp?year=2008&rollnumber=60 \|access-date=February 14, 2008 \|archive-date=February 27, 2008 \|archive-url=https://web.archive.org/web/20080227201816/http://clerk.house.gov/cgi-bin/vote.asp?year=2008&rollnumber=60 \|url-status=live }} \| rowspan="2" \| 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, White House Chief of Staff
Eric Holder, Attorney General \|June 20, 2012 House Committee on Oversight and Government Reform{{cite news \|last=Perez \|first=Evan \|title=House Panel Votes to Hold Holder in Contempt \|url=https://www.wsj.com/articles/SB10001424052702304898704577478370452447012 \|access-date=June 20, 2012 \|newspaper=The Wall Street Journal \|date=June 20, 2012 \|archive-date=September 30, 2019 \|archive-url=https://web.archive.org/web/20190930160327/https://www.wsj.com/articles/SB10001424052702304898704577478370452447012 \|url-status=live }} \|June 28, 2012 House of Representatives \|Found in contempt by a vote of 255–67{{cite web \|title=Final Vote Results for Roll Call 441 \|publisher=Clerk of the United States House of Representatives \|date=June 28, 2012 \|url=http://clerk.house.gov/evs/2012/roll441.xml \|access-date=June 29, 2012 \|archive-date=October 17, 2012 \|archive-url=https://web.archive.org/web/20121017062627/http://clerk.house.gov/evs/2012/roll441.xml \|url-status=live }}{{cite web \|title=Final Vote Results for Roll Call 442 \|publisher=Clerk of the United States House of Representatives \|date=June 28, 2012 \|url=http://clerk.house.gov/evs/2012/roll442.xml \|access-date=June 29, 2012 \|archive-date=October 17, 2012 \|archive-url=https://web.archive.org/web/20121017062636/http://clerk.house.gov/evs/2012/roll442.xml \|url-status=live }}
Lois Lerner Director of the IRS Exempt Organizations Division \|March 11, 2014 House Committee on Oversight and Government Reform{{cite web\|url=http://oversight.house.gov/report/staff-report-lois-lerners-involvement-irs-targeting-tax-exempt-organizations/\|title=Lois Lerner's Involvement in the IRS Targeting of Tax-Exempt Organizations\|publisher=United States House Committee on Oversight and Government Reform\|website=house.gov\|access-date=May 18, 2017\|archive-url=https://web.archive.org/web/20181225142600/http://oversight.house.gov/report/staff-report-lois-lerners-involvement-irs-targeting-tax-exempt-organizations/\|archive-date=December 25, 2018\|url-status=dead}} \|May 7, 2014{{cite web\|url=https://www.foxnews.com/politics/house-votes-to-hold-lerner-in-contempt-of-congress\|title=House votes to hold Lerner in contempt of Congress\|date=May 7, 2014\|website=Fox News\|access-date=May 18, 2017\|archive-date=October 23, 2015\|archive-url=https://web.archive.org/web/20151023072634/http://www.foxnews.com/politics/2014/05/07/house-votes-to-hold-lerner-in-contempt-congress/\|url-status=live}} House of Representatives \|Found in contempt for her role in the 2013 IRS controversy and refusal to testify. The Department of Justice declined to prosecute. (See: Finding Lois Lerner in contempt of Congress (H.Res. 574; 113th Congress))
Bryan Pagliano IT director, Hillary Clinton aide \|September 13, 2016 House Committee on Oversight and Government Reform{{cite web\|url=https://www.politico.com/story/2016/09/bryan-pagliano-contempt-house-panel-228520\|title=House panel votes to hold Clinton tech aide Bryan Pagliano in contempt\|first=Josh\|last=Gerstein\|website=Politico\|date=September 22, 2016 \|access-date=2018-11-17\|archive-url=https://web.archive.org/web/20181019213057/https://www.politico.com/story/2016/09/bryan-pagliano-contempt-house-panel-228520\|archive-date=2018-10-19}}{{cite web\|url=https://oversight.house.gov/hearing/examining-preservation-state-department-records/\|title=Examining Preservation of State Department Records \|publisher=United States House Committee on Oversight and Government Reform\|website=oversight.house.gov\|access-date=May 18, 2017\|archive-url=https://web.archive.org/web/20180921224359/https://oversight.house.gov/hearing/examining-preservation-state-department-records/\|archive-date=2018-09-21\|quote=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.}} \| Not considered \|House 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.{{cite web\|url=https://oversight.house.gov/hearing/examining-preservation-state-department-records-2/\|title=Examining Preservation of State Department Federal Records \|publisher=United States House Committee on Oversight and Government Reform\|website=oversight.house.gov\|access-date=May 18, 2017\|archive-url=https://web.archive.org/web/20180922151432/https://oversight.house.gov/hearing/examining-preservation-state-department-records-2/\|archive-date=2018-09-22}} 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."{{cite press release \|date=2017-02-17 \|title=Chaffetz Asks Justice Department to Uphold Institutional Interests of Congress \|url=https://oversight.house.gov/release/chaffetz-asks-justice-department-uphold-institutional-interests-congress/ \|publisher=United States House Committee on Oversight and Government Reform \|access-date=2018-11-17\|archive-url=https://web.archive.org/web/20181005065628/https://oversight.house.gov/release/chaffetz-asks-justice-department-uphold-institutional-interests-congress/\|archive-date=2018-10-05}} [https://web.archive.org/web/20181001200720/https://oversight.house.gov/wp-content/uploads/2017/02/2017-02-16-JEC-to-Sessions-DOJ-Criminal-Referral-on-Contempt.pdf Archived letter].
Backpage.com \|March 17, 2016 Senate Homeland Security Permanent Subcommittee on Investigations \|March 17, 2016{{cite web\|url=https://www.hsgac.senate.gov/subcommittees/investigations/media/senate-passes-portman-resolution-to-hold-backpagecom-in-contempt-of-congress\|title=Homeland Security & Governmental Affairs Committee\|website=www.hsgac.senate.gov\|access-date=May 18, 2017\|archive-date=May 8, 2019\|archive-url=https://web.archive.org/web/20190508201748/https://www.hsgac.senate.gov/subcommittees/investigations/media/senate-passes-portman-resolution-to-hold-backpagecom-in-contempt-of-congress\|url-status=live}} Senate \|Found in contempt for failing to provide documents in an investigation into human trafficking.
William P. Barr, United States Attorney General Wilbur Ross, United States Secretary of Commerce \|House Committee on Oversight and Reform \|July 17, 2019, House of Representatives{{cite web\|url=http://clerk.house.gov/evs/2019/roll489.xml\|title=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\|access-date=September 17, 2019\|archive-date=December 18, 2019\|archive-url=https://web.archive.org/web/20191218044720/http://clerk.house.gov/evs/2019/roll489.xml\|url-status=live}} \|Refusal to Comply with Subpoenas Duly Issued by the Committee on Oversight and Reform
Chad Wolf, United States Secretary of Homeland Security \|September 17, 2020 House Homeland Security Committee{{Cite news\|url=https://edition.cnn.com/2020/09/17/politics/chad-wolf-house-subpoena/index.html\|title=Chad Wolf defies Subpoena impeached after historic vote\|date=2019-12-19\|access-date=2019-12-24\|language=en-GB\|archive-date=February 14, 2021\|archive-url=https://web.archive.org/web/20210214030659/https://edition.cnn.com/2020/09/17/politics/chad-wolf-house-subpoena/index.html\|url-status=live}} \|Not considered \|Acting Homeland Secretary Chad Wolf defies subpoena and skips House hearing as he faces whistleblower allegations that he urged department officials to alter intelligence.
Steve Bannon \|October 18, 2021 House Select Committee on the January 6 Attack{{Cite news\|date=2021-11-13\|title=Steve Bannon Indicted for Criminal Contempt of Congress - November 13, 2021\|url=https://dailynewsbrief.com/2021/11/13/steve-bannon-indicted-for-criminal-contempt-of-congress/\|access-date=2021-11-15\|website=Daily News Brief\|language=en-US}} \|October 21, 2021, House of Representatives \|Found guilty by a Federal Jury of unlawfully defying a subpoena issued by the January 6th Committee. Sentenced to 4 months in prison. Began serving his four-month prison sentence on July 1, 2024, after his appeal was rejected by the Supreme Court.{{cite news\|date=2024-07-01\|url=https://apnews.com/article/steve-bannon-contempt-sentence-federal-prison-trump-77353a10250c36f77b2c1b7d188c5250\|title=Trump ally Steve Bannon surrenders to federal prison to serve 4-month sentence on contempt charges\|access-date=1 July 2024\|website=Associated Press\|language=en}}
Mark Meadows, White House Chief of Staff \|December 13, 2021 House Select Committee on the January 6 Attack{{cite web \|url=https://www.usatoday.com/story/news/politics/2021/12/13/mark-meadows-house-contempt/6493528001/\|title=Former Trump chief of staff Mark Meadows held in contempt by House Jan. 6 committee \|first=Bart\|last=Jansen\|work=USA Today\|date=2021-12-13\|access-date=2024-01-12}} \|House of Representatives \|On December 14, 2021, House of Representatives voted 222–203 to hold Meadows in contempt for defying a January 6 Committee subpoena.{{cite news\|last1=Dickson \|first1=Caitlyn\|title=House votes for Meadows to face criminal charges for defying Jan. 6 probe\|url=https://news.yahoo.com/house-votes-for-meadows-to-face-criminal-charges-for-defying-jan-6-probe-041359696.html \|date=December 14, 2021\|access-date=December 14, 2021\|website=Yahoo! News\|language=en}}{{cite news\|url=https://www.independent.co.uk/news/world/americas/us-politics/mark-meadows-capitol-riot-congress-contempt-b1976232.html\|title=Mark Meadows: House votes to hold ex-Trump aide in contempt of Congress and refers him for prosecution\|first1=Andrew\|last1=Feinberg\|first2=Eric\|last2=Garcia\|work=The Independent\|date=December 15, 2021\|accessdate=July 1, 2024}}
Peter Navarro, White House Adviser \|February 23, 2022 House Select Committee on the January 6 Attack \|House of Representatives \|Found guilty by a Federal Jury of contempt of Congress by unlawfully defying a subpoena issued by the January 6th Committee on September 7, 2023. Began serving his 4-month sentence on March 19, 2024, after his appeal was rejected by the Supreme Court.{{Cite web\|date=2024-03-19\|title=Ex-Trump adviser Peter Navarro reports to prison on contempt of Congress conviction\|url=https://www.nbcnews.com/politics/justice-department/ex-trump-adviser-peter-navarro-reports-prison-contempt-congress-convic-rcna144043\|access-date=May 16, 2024\|website=NBC News\|language=en-US}}
Dan Scavino, White House Deputy Chief of Staff for Communications \|February 23, 2022 House Select Committee on the January 6 Attack \|House of Representatives \|On April 6, 2022, House of Representatives voted 220–203 to hold Scavino in contempt for defying a January 6 Committee subpoena.{{cite news\|url=https://www.politico.com/news/2022/04/06/house-votes-dan-scavino-peter-navarro-in-contempt-00023619\|title=House votes to hold Dan Scavino and Peter Navarro in contempt\|first1=Nicholas\|last1=Wu\|first2=Kyle\|last2=Cheney\|publisher=Politico\|date=April 6, 2022\|accessdate=July 1, 2024}}
Hunter Biden, son of President Joe Biden \|January 10, 2024 House Committee on the Judiciary, House Committee on Oversight and Reform{{cite news\|url=https://www.nbcnews.com/politics/congress/house-republicans-vote-resolutions-hold-hunter-biden-contempt-congress-rcna133206\|title=GOP-led committees vote to recommend that House hold Hunter Biden in contempt\|first1=Sarah\|last1=Fitzpatrick\|first2=Summer\|last2=Concepcion\|first3=Zoë\|last3=Richards\|publisher=NBC News\|date=January 10, 2024\|accessdate=January 12, 2024}} \|House of Representatives{{cite news\|url=https://www.cbsnews.com/news/hunter-biden-contempt-of-congress-house-vote/\|title=House to vote next week on holding Hunter Biden in contempt of Congress\|first=Kathryn\|last=Watson\|publisher=CBS News\|date=January 12, 2024\|accessdate=January 12, 2024}} \|Biden agrees to provide a deposition to Committee on Oversight and Reform.{{Cite web \|date=2024-01-18 \|title=Hunter Biden agrees to deposition with House Republican after months of defiance, committee says \|url=https://apnews.com/article/hunter-biden-congress-contempt-subpoena-058b67e9d69bd12d14b8e395c2aadaf0 \|access-date=2024-01-19 \|website=AP News \|language=en}}
Merrick Garland, U.S. Attorney General \|June 12, 2024 House Committee on the Judiciary \|House of Representatives \|Found in contempt by a 216–207 vote for refusing to comply with subpoenas from the House Judiciary and Oversight committees.{{Cite web \|url=https://www.cbsnews.com/news/house-vote-merrick-garland-contempt-biden-audio-recordings/ \|title=House votes to hold Attorney General Merrick Garland in contempt for withholding Biden audio \|date=June 12, 2024 \|last=Yilek \|first=Caitlin \|publisher=CBS News \|access-date=June 12, 2024}}
Merrick Garland, U.S. Attorney General \|July 10, 2024 Brought forward by a privileged resolution written by U.S. Representative Anna Paulina Luna{{cite web \|last1=Brooks \|first1=Emily \|title=Luna moves to force vote on fining Garland $10,000 per day \|url=https://thehill.com/homenews/house/4764541-luna-garland-inherent-contempt/ \|work=The Hill \|access-date=23 September 2024 \|date=10 July 2024}} \|House of Representatives{{cite web \|last1=Tarinelli \|first1=Ryan \|title=House rejects 'inherent contempt' resolution for Garland over tape of Biden interview \|url=https://rollcall.com/2024/07/11/house-rejects-inherent-contempt-resolution-for-garland-over-tape-of-biden-interview/ \|publisher=Roll Call \|access-date=23 September 2024 \|date=11 July 2024}} \|On July 11, the United States House of Representatives found Garland not in "inherent contempt" by a 204–210 vote.{{cite web \|last1=Wong \|first1=Scott \|last2=Stewart \|first2=Kyle \|title=Republicans fail to hold AG Merrick Garland in contempt and fine him over Biden audiotapes \|url=https://www.nbcnews.com/politics/congress/republican-bill-hold-ag-garland-contempt-fine-biden-audiotapes-fails-rcna160898 \|publisher=NBC News \|access-date=23 September 2024 \|date=11 July 2024}}
Ralph de la Torre, CEO of Steward Health Care \|September 19, 2024{{Cite news \|last=Pressman \|first=Aaron \|date=September 19, 2024 \|title=Senate panel votes to hold Steward CEO Ralph de la Torre in contempt \|url=https://www.bostonglobe.com/2024/09/19/business/senate-looks-punish-steward-ceo-de-la-torre-failure-testify/?p1=Article_Inline_Text_Link \|archive-url=https://web.archive.org/web/20240925232737/https://www.bostonglobe.com/2024/09/19/business/senate-looks-punish-steward-ceo-de-la-torre-failure-testify/?p1=Article_Inline_Text_Link \|archive-date=September 25, 2024 \|access-date=September 25, 2024 \|work=The Boston Globe}} Senate Committee on Health, Education, Labor and Pensions (HELP) \|Senate{{Cite news \|last=Yang \|first=Maya \|date=September 25, 2024 \|title=US Senate votes unanimously to hold hospital CEO in criminal contempt \|url=https://www.theguardian.com/us-news/2024/sep/25/ralph-de-la-torre-congress-criminal-contempt \|archive-url=https://web.archive.org/web/20240925230857/https://www.theguardian.com/us-news/2024/sep/25/ralph-de-la-torre-congress-criminal-contempt \|archive-date=September 25, 2024 \|access-date=September 25, 2024 \|work=The Guardian}} \|Found in criminal contempt by unanimous consent on September 25, 2024. Certification of civil contempt charge is pending submission of a report by the HELP Committee.{{Cite news \|last1=Pressman \|first1=Aaron \|last2=Puzzanghera \|first2=Jim \|date=September 25, 2024 \|title=Steward CEO could face prison time after rare Senate vote to punish him for flouting subpoena \|url=https://www.bostonglobe.com/2024/09/25/business/ralph-de-la-torre-contempt-charge-senate-justice-department/ \|archive-url=https://web.archive.org/web/20240925233305/https://www.bostonglobe.com/2024/09/25/business/ralph-de-la-torre-contempt-charge-senate-justice-department/ \|archive-date=September 25, 2024 \|access-date=September 25, 2024 \|work=The Boston Globe}}
Antony Blinken, U.S. Secretary of State \|September 24, 2024 House Foreign Affairs Committee{{cite web \|last1=Zengerle \|first1=Patricia \|title=US House committee recommends contempt charge for Blinken \|url=https://www.reuters.com/world/us/us-house-committee-recommends-contempt-charge-blinken-2024-09-24/ \|work=Reuters \|access-date=24 September 2024 \|date=24 September 2024}} \|Not considered \|The full House of Representatives has not yet scheduled a vote on the committee's recommendation. However, the Speaker of the House of Representatives, Mike Johnson, commented that he expected the measure would likely not be taken up for a vote until after the presidential election.{{cite web \|last1=Amiri \|first1=Farnoush \|last2=Lee \|first2=Matthew \|title=House Republicans advance contempt charges against Secretary Blinken over Afghanistan testimony \|url=https://apnews.com/article/blinken-mccaul-afghanistan-withdrawal-kabul-trump-biden-harris-republican-0a496c8a30065e6773a1fcc60fdcd775 \|work=Associated Press News \|access-date=24 September 2024 \|date=24 September 2024}}

class="wikitable sortable" style="font-size: 90%;"

Person

! Subcommittee/Committee

! Chamber

! Ultimate Disposition

Rogers C.B. Morton,
Secretary of Commerce

| November 11, 1975
Subcommittee of the House Committee on Interstate and Foreign Commerce

| Not considered

| Morton released the material to the subcommittee.

Henry Kissinger,
Secretary of State

| November 15, 1975
House Select Committee on Intelligence

| Not considered

| Citation dismissed after "substantial compliance" with subpoena.

Joseph A. Califano Jr.,
Secretary of Health, Education, and Welfare

| August 6, 1978
Subcommittee of the House Committee on Interstate and Foreign Commerce

| Not considered

| Califano complied with the subpoena about one month after the subcommittee citation.

Charles W. Duncan Jr.,
Secretary of Energy

| April 29, 1980
Subcommittee of the House Committee on Government Operations

| Not considered

| Duncan supplied the material by May 14, 1980.

James B. Edwards,
Secretary of Energy

| July 23, 1981
Environment, Energy, and Natural Resources Subcommittee of the House Committee on Government Operations

| Not considered

| Documents were delivered to Congress prior to full Committee consideration of the contempt citation.

James G. Watt,
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 considered

| The 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,
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 Representatives

| U.S. Attorney Stanley S. Harris never presented the case to a Grand Jury as required by law.{{Cite news|last1=Maitland|first1=Leslie|date=1983-03-14|title=U.S. ATTORNEY SAID TO ACT ON HIS OWN IN NOT PRESSING BURFORD CASE|language=en-US|newspaper=The New York Times|url=https://www.nytimes.com/1983/03/14/us/us-attorney-said-to-act-on-his-own-in-not-pressing-burford-case.html|access-date=2021-05-09|issn=0362-4331}} After legal cases and a court dismissal of the Executive Branch's suit, the parties reached an agreement to provide documents and withdrew contempt citation.

Rita Lavelle,
EPA official

| April 26, 1983
House Committee on Energy and Commerce

| House of Representatives

| Indicted for contempt of Congress, but acquitted in trial;{{cite web|url=https://www.washingtonpost.com/history/2021/11/13/steve-bannon-contempt-congress-rita-lavelle/|title=Decades before Steve Bannon was charged with contempt of Congress, Rita Lavelle was tried|author=Timothy Bella|date=November 13, 2021|website=washingtonpost.com}} Later convicted for lying to Congress and sentenced to 6 months in prison, 5 years probation thereafter, and a fine of $10,000.{{cite news|last=Shabecoff|first=Philip|date=January 10, 1984|title=Rita Lavelle gets 6-month term and is fined $10,000 for perjury|newspaper=The New York Times|page=A1|url=https://www.nytimes.com/1984/01/10/us/rita-lavelle-gets-6-month-term-and-is-fined-10000-for-perjury.html|access-date=July 1, 2024}}{{cite news | publisher = content.time.com | date = December 12, 1983 | title = Costly Lies: Rita Lavelle is convicted of perjury | url = http://content.time.com/time/magazine/article/0,9171,921404,00.html}}

Jack Quinn,
White House Counsel

| rowspan="2" | May 9, 1996
House Committee on Oversight and Government Reform

| rowspan="2" | Not considered

| rowspan="2" | Subpoenaed 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,
Attorney General

| August 6, 1998
House Committee on Oversight and Government Reform

| Not considered

| The majority of documents in question were released following the conclusion of the Department of Justice investigation into campaign finance violations of 1996. However, an additional memo was withheld and later claimed as privileged by the George W. Bush administration.{{Cite news|last=Marquis|first=Christopher|date=2000-05-19|title=F.B.I. Memo Details Freeh Warning to Reno|language=en-US|newspaper=The New York Times|url=https://www.nytimes.com/2000/05/19/us/fbi-memo-details-freeh-warning-to-reno.html|access-date=2021-05-09|issn=0362-4331}}

Harriet Miers,
Former White House Counsel

| rowspan="2" | July 25, 2007
House Committee on the Judiciary{{cite news |last=Stout |first=David |title=Panel Holds Two Bush Aides in Contempt |work=The New York Times |date=July 25, 2007 |url=https://www.nytimes.com/2007/07/25/washington/25cnd-contempt.html |access-date=July 26, 2007 |archive-date=April 17, 2014 |archive-url=https://web.archive.org/web/20140417111153/http://www.nytimes.com/2007/07/25/washington/25cnd-contempt.html |url-status=live }}

| rowspan="2" | February 14, 2008 House of Representatives{{cite web |title=Final Vote Results for Roll Call 60 |publisher=Clerk of the United States House of Representatives |date=February 14, 2008 |url=http://clerk.house.gov/cgi-bin/vote.asp?year=2008&rollnumber=60 |access-date=February 14, 2008 |archive-date=February 27, 2008 |archive-url=https://web.archive.org/web/20080227201816/http://clerk.house.gov/cgi-bin/vote.asp?year=2008&rollnumber=60 |url-status=live }}

| rowspan="2" | 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, White House Chief of Staff

Eric Holder, Attorney General

|June 20, 2012
House Committee on Oversight and Government Reform{{cite news |last=Perez |first=Evan |title=House Panel Votes to Hold Holder in Contempt |url=https://www.wsj.com/articles/SB10001424052702304898704577478370452447012 |access-date=June 20, 2012 |newspaper=The Wall Street Journal |date=June 20, 2012 |archive-date=September 30, 2019 |archive-url=https://web.archive.org/web/20190930160327/https://www.wsj.com/articles/SB10001424052702304898704577478370452447012 |url-status=live }}

|June 28, 2012 House of Representatives

|Found in contempt by a vote of 255–67{{cite web |title=Final Vote Results for Roll Call 441 |publisher=Clerk of the United States House of Representatives |date=June 28, 2012 |url=http://clerk.house.gov/evs/2012/roll441.xml |access-date=June 29, 2012 |archive-date=October 17, 2012 |archive-url=https://web.archive.org/web/20121017062627/http://clerk.house.gov/evs/2012/roll441.xml |url-status=live }}{{cite web |title=Final Vote Results for Roll Call 442 |publisher=Clerk of the United States House of Representatives |date=June 28, 2012 |url=http://clerk.house.gov/evs/2012/roll442.xml |access-date=June 29, 2012 |archive-date=October 17, 2012 |archive-url=https://web.archive.org/web/20121017062636/http://clerk.house.gov/evs/2012/roll442.xml |url-status=live }}

Lois Lerner
Director of the IRS Exempt Organizations Division

|March 11, 2014
House Committee on Oversight and Government Reform{{cite web|url=http://oversight.house.gov/report/staff-report-lois-lerners-involvement-irs-targeting-tax-exempt-organizations/|title=Lois Lerner's Involvement in the IRS Targeting of Tax-Exempt Organizations|publisher=United States House Committee on Oversight and Government Reform|website=house.gov|access-date=May 18, 2017|archive-url=https://web.archive.org/web/20181225142600/http://oversight.house.gov/report/staff-report-lois-lerners-involvement-irs-targeting-tax-exempt-organizations/|archive-date=December 25, 2018|url-status=dead}}

|May 7, 2014{{cite web|url=https://www.foxnews.com/politics/house-votes-to-hold-lerner-in-contempt-of-congress|title=House votes to hold Lerner in contempt of Congress|date=May 7, 2014|website=Fox News|access-date=May 18, 2017|archive-date=October 23, 2015|archive-url=https://web.archive.org/web/20151023072634/http://www.foxnews.com/politics/2014/05/07/house-votes-to-hold-lerner-in-contempt-congress/|url-status=live}} House of Representatives

|Found in contempt for her role in the 2013 IRS controversy and refusal to testify. The Department of Justice declined to prosecute. (See: Finding Lois Lerner in contempt of Congress (H.Res. 574; 113th Congress))

Bryan Pagliano
IT director, Hillary Clinton aide

|September 13, 2016
House Committee on Oversight and Government Reform{{cite web|url=https://www.politico.com/story/2016/09/bryan-pagliano-contempt-house-panel-228520|title=House panel votes to hold Clinton tech aide Bryan Pagliano in contempt|first=Josh|last=Gerstein|website=Politico|date=September 22, 2016 |access-date=2018-11-17|archive-url=https://web.archive.org/web/20181019213057/https://www.politico.com/story/2016/09/bryan-pagliano-contempt-house-panel-228520|archive-date=2018-10-19}}{{cite web|url=https://oversight.house.gov/hearing/examining-preservation-state-department-records/|title=Examining Preservation of State Department Records |publisher=United States House Committee on Oversight and Government Reform|website=oversight.house.gov|access-date=May 18, 2017|archive-url=https://web.archive.org/web/20180921224359/https://oversight.house.gov/hearing/examining-preservation-state-department-records/|archive-date=2018-09-21|quote=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.}}

| Not considered

|House 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.{{cite web|url=https://oversight.house.gov/hearing/examining-preservation-state-department-records-2/|title=Examining Preservation of State Department Federal Records |publisher=United States House Committee on Oversight and Government Reform|website=oversight.house.gov|access-date=May 18, 2017|archive-url=https://web.archive.org/web/20180922151432/https://oversight.house.gov/hearing/examining-preservation-state-department-records-2/|archive-date=2018-09-22}} 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."{{cite press release |date=2017-02-17 |title=Chaffetz Asks Justice Department to Uphold Institutional Interests of Congress |url=https://oversight.house.gov/release/chaffetz-asks-justice-department-uphold-institutional-interests-congress/ |publisher=United States House Committee on Oversight and Government Reform |access-date=2018-11-17|archive-url=https://web.archive.org/web/20181005065628/https://oversight.house.gov/release/chaffetz-asks-justice-department-uphold-institutional-interests-congress/|archive-date=2018-10-05}} [https://web.archive.org/web/20181001200720/https://oversight.house.gov/wp-content/uploads/2017/02/2017-02-16-JEC-to-Sessions-DOJ-Criminal-Referral-on-Contempt.pdf Archived letter].

Backpage.com

|March 17, 2016
Senate Homeland Security Permanent Subcommittee on Investigations

|March 17, 2016{{cite web|url=https://www.hsgac.senate.gov/subcommittees/investigations/media/senate-passes-portman-resolution-to-hold-backpagecom-in-contempt-of-congress|title=Homeland Security & Governmental Affairs Committee|website=www.hsgac.senate.gov|access-date=May 18, 2017|archive-date=May 8, 2019|archive-url=https://web.archive.org/web/20190508201748/https://www.hsgac.senate.gov/subcommittees/investigations/media/senate-passes-portman-resolution-to-hold-backpagecom-in-contempt-of-congress|url-status=live}} Senate

|Found in contempt for failing to provide documents in an investigation into human trafficking.

William P. Barr, United States Attorney General

Wilbur Ross, United States Secretary of Commerce

|House Committee on Oversight and Reform

|July 17, 2019, House of Representatives{{cite web|url=http://clerk.house.gov/evs/2019/roll489.xml|title=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|access-date=September 17, 2019|archive-date=December 18, 2019|archive-url=https://web.archive.org/web/20191218044720/http://clerk.house.gov/evs/2019/roll489.xml|url-status=live}}

|Refusal to Comply with Subpoenas Duly Issued by the Committee on Oversight and Reform

Chad Wolf, United States Secretary of Homeland Security

|September 17, 2020
House Homeland Security Committee{{Cite news|url=https://edition.cnn.com/2020/09/17/politics/chad-wolf-house-subpoena/index.html|title=Chad Wolf defies Subpoena impeached after historic vote|date=2019-12-19|access-date=2019-12-24|language=en-GB|archive-date=February 14, 2021|archive-url=https://web.archive.org/web/20210214030659/https://edition.cnn.com/2020/09/17/politics/chad-wolf-house-subpoena/index.html|url-status=live}}

|Not considered

|Acting Homeland Secretary Chad Wolf defies subpoena and skips House hearing as he faces whistleblower allegations that he urged department officials to alter intelligence.

Steve Bannon

|October 18, 2021

House Select Committee on the January 6 Attack{{Cite news|date=2021-11-13|title=Steve Bannon Indicted for Criminal Contempt of Congress - November 13, 2021|url=https://dailynewsbrief.com/2021/11/13/steve-bannon-indicted-for-criminal-contempt-of-congress/|access-date=2021-11-15|website=Daily News Brief|language=en-US}}

|October 21, 2021, House of Representatives

|Found guilty by a Federal Jury of unlawfully defying a subpoena issued by the January 6th Committee. Sentenced to 4 months in prison. Began serving his four-month prison sentence on July 1, 2024, after his appeal was rejected by the Supreme Court.{{cite news|date=2024-07-01|url=https://apnews.com/article/steve-bannon-contempt-sentence-federal-prison-trump-77353a10250c36f77b2c1b7d188c5250|title=Trump ally Steve Bannon surrenders to federal prison to serve 4-month sentence on contempt charges|access-date=1 July 2024|website=Associated Press|language=en}}

Mark Meadows, White House Chief of Staff

|December 13, 2021

House Select Committee on the January 6 Attack{{cite web |url=https://www.usatoday.com/story/news/politics/2021/12/13/mark-meadows-house-contempt/6493528001/|title=Former Trump chief of staff Mark Meadows held in contempt by House Jan. 6 committee |first=Bart|last=Jansen|work=USA Today|date=2021-12-13|access-date=2024-01-12}}

|House of Representatives

|On December 14, 2021, House of Representatives voted 222–203 to hold Meadows in contempt for defying a January 6 Committee subpoena.{{cite news|last1=Dickson |first1=Caitlyn|title=House votes for Meadows to face criminal charges for defying Jan. 6 probe|url=https://news.yahoo.com/house-votes-for-meadows-to-face-criminal-charges-for-defying-jan-6-probe-041359696.html |date=December 14, 2021|access-date=December 14, 2021|website=Yahoo! News|language=en}}{{cite news|url=https://www.independent.co.uk/news/world/americas/us-politics/mark-meadows-capitol-riot-congress-contempt-b1976232.html|title=Mark Meadows: House votes to hold ex-Trump aide in contempt of Congress and refers him for prosecution|first1=Andrew|last1=Feinberg|first2=Eric|last2=Garcia|work=The Independent|date=December 15, 2021|accessdate=July 1, 2024}}

Peter Navarro, White House Adviser

|February 23, 2022

House Select Committee on the January 6 Attack

|House of Representatives

|Found guilty by a Federal Jury of contempt of Congress by unlawfully defying a subpoena issued by the January 6th Committee on September 7, 2023. Began serving his 4-month sentence on March 19, 2024, after his appeal was rejected by the Supreme Court.{{Cite web|date=2024-03-19|title=Ex-Trump adviser Peter Navarro reports to prison on contempt of Congress conviction|url=https://www.nbcnews.com/politics/justice-department/ex-trump-adviser-peter-navarro-reports-prison-contempt-congress-convic-rcna144043|access-date=May 16, 2024|website=NBC News|language=en-US}}

Dan Scavino, White House Deputy Chief of Staff for Communications

|February 23, 2022

House Select Committee on the January 6 Attack

|House of Representatives

|On April 6, 2022, House of Representatives voted 220–203 to hold Scavino in contempt for defying a January 6 Committee subpoena.{{cite news|url=https://www.politico.com/news/2022/04/06/house-votes-dan-scavino-peter-navarro-in-contempt-00023619|title=House votes to hold Dan Scavino and Peter Navarro in contempt|first1=Nicholas|last1=Wu|first2=Kyle|last2=Cheney|publisher=Politico|date=April 6, 2022|accessdate=July 1, 2024}}

Hunter Biden, son of President Joe Biden

|January 10, 2024

House Committee on the Judiciary, House Committee on Oversight and Reform{{cite news|url=https://www.nbcnews.com/politics/congress/house-republicans-vote-resolutions-hold-hunter-biden-contempt-congress-rcna133206|title=GOP-led committees vote to recommend that House hold Hunter Biden in contempt|first1=Sarah|last1=Fitzpatrick|first2=Summer|last2=Concepcion|first3=Zoë|last3=Richards|publisher=NBC News|date=January 10, 2024|accessdate=January 12, 2024}}

|House of Representatives{{cite news|url=https://www.cbsnews.com/news/hunter-biden-contempt-of-congress-house-vote/|title=House to vote next week on holding Hunter Biden in contempt of Congress|first=Kathryn|last=Watson|publisher=CBS News|date=January 12, 2024|accessdate=January 12, 2024}}

|Biden agrees to provide a deposition to Committee on Oversight and Reform.{{Cite web |date=2024-01-18 |title=Hunter Biden agrees to deposition with House Republican after months of defiance, committee says |url=https://apnews.com/article/hunter-biden-congress-contempt-subpoena-058b67e9d69bd12d14b8e395c2aadaf0 |access-date=2024-01-19 |website=AP News |language=en}}

Merrick Garland, U.S. Attorney General

|June 12, 2024

House Committee on the Judiciary

|House of Representatives

|Found in contempt by a 216–207 vote for refusing to comply with subpoenas from the House Judiciary and Oversight committees.{{Cite web |url=https://www.cbsnews.com/news/house-vote-merrick-garland-contempt-biden-audio-recordings/ |title=House votes to hold Attorney General Merrick Garland in contempt for withholding Biden audio |date=June 12, 2024 |last=Yilek |first=Caitlin |publisher=CBS News |access-date=June 12, 2024}}

Merrick Garland, U.S. Attorney General

|July 10, 2024

Brought forward by a privileged resolution written by U.S. Representative Anna Paulina Luna{{cite web |last1=Brooks |first1=Emily |title=Luna moves to force vote on fining Garland $10,000 per day |url=https://thehill.com/homenews/house/4764541-luna-garland-inherent-contempt/ |work=The Hill |access-date=23 September 2024 |date=10 July 2024}}

|House of Representatives{{cite web |last1=Tarinelli |first1=Ryan |title=House rejects 'inherent contempt' resolution for Garland over tape of Biden interview |url=https://rollcall.com/2024/07/11/house-rejects-inherent-contempt-resolution-for-garland-over-tape-of-biden-interview/ |publisher=Roll Call |access-date=23 September 2024 |date=11 July 2024}}

|On July 11, the United States House of Representatives found Garland not in "inherent contempt" by a 204–210 vote.{{cite web |last1=Wong |first1=Scott |last2=Stewart |first2=Kyle |title=Republicans fail to hold AG Merrick Garland in contempt and fine him over Biden audiotapes |url=https://www.nbcnews.com/politics/congress/republican-bill-hold-ag-garland-contempt-fine-biden-audiotapes-fails-rcna160898 |publisher=NBC News |access-date=23 September 2024 |date=11 July 2024}}

Ralph de la Torre, CEO of Steward Health Care

|September 19, 2024{{Cite news |last=Pressman |first=Aaron |date=September 19, 2024 |title=Senate panel votes to hold Steward CEO Ralph de la Torre in contempt |url=https://www.bostonglobe.com/2024/09/19/business/senate-looks-punish-steward-ceo-de-la-torre-failure-testify/?p1=Article_Inline_Text_Link |archive-url=https://web.archive.org/web/20240925232737/https://www.bostonglobe.com/2024/09/19/business/senate-looks-punish-steward-ceo-de-la-torre-failure-testify/?p1=Article_Inline_Text_Link |archive-date=September 25, 2024 |access-date=September 25, 2024 |work=The Boston Globe}}

Senate Committee on Health, Education, Labor and Pensions (HELP)

|Senate{{Cite news |last=Yang |first=Maya |date=September 25, 2024 |title=US Senate votes unanimously to hold hospital CEO in criminal contempt |url=https://www.theguardian.com/us-news/2024/sep/25/ralph-de-la-torre-congress-criminal-contempt |archive-url=https://web.archive.org/web/20240925230857/https://www.theguardian.com/us-news/2024/sep/25/ralph-de-la-torre-congress-criminal-contempt |archive-date=September 25, 2024 |access-date=September 25, 2024 |work=The Guardian}}

|Found in criminal contempt by unanimous consent on September 25, 2024. Certification of civil contempt charge is pending submission of a report by the HELP Committee.{{Cite news |last1=Pressman |first1=Aaron |last2=Puzzanghera |first2=Jim |date=September 25, 2024 |title=Steward CEO could face prison time after rare Senate vote to punish him for flouting subpoena |url=https://www.bostonglobe.com/2024/09/25/business/ralph-de-la-torre-contempt-charge-senate-justice-department/ |archive-url=https://web.archive.org/web/20240925233305/https://www.bostonglobe.com/2024/09/25/business/ralph-de-la-torre-contempt-charge-senate-justice-department/ |archive-date=September 25, 2024 |access-date=September 25, 2024 |work=The Boston Globe}}

Antony Blinken, U.S. Secretary of State

|September 24, 2024

House Foreign Affairs Committee{{cite web |last1=Zengerle |first1=Patricia |title=US House committee recommends contempt charge for Blinken |url=https://www.reuters.com/world/us/us-house-committee-recommends-contempt-charge-blinken-2024-09-24/ |work=Reuters |access-date=24 September 2024 |date=24 September 2024}}

|Not considered

|The full House of Representatives has not yet scheduled a vote on the committee's recommendation. However, the Speaker of the House of Representatives, Mike Johnson, commented that he expected the measure would likely not be taken up for a vote until after the presidential election.{{cite web |last1=Amiri |first1=Farnoush |last2=Lee |first2=Matthew |title=House Republicans advance contempt charges against Secretary Blinken over Afghanistan testimony |url=https://apnews.com/article/blinken-mccaul-afghanistan-withdrawal-kabul-trump-biden-harris-republican-0a496c8a30065e6773a1fcc60fdcd775 |work=Associated Press News |access-date=24 September 2024 |date=24 September 2024}}

References

External links

{{cite web |url= http://www.fas.org/sgp/crs/misc/RL34097.pdf |title= Congress's Contempt Power: Law, History, Practice, and Procedure |publisher= Congressional Research Service |date= May 12, 2017}}
{{cite journal |first= Michael A. |last= Zuckerman |url= http://student.virginia.edu/~jalopy/uploads/Zuckerman%2025-1.pdf |archive-url= https://web.archive.org/web/20100415054530/http://student.virginia.edu/~jalopy/uploads/Zuckerman%2025-1.pdf |url-status=dead |archive-date= 2010-04-15 |title= The Court of Congressional Contempt |journal= Journal of Law and Politics |volume= 25 |pages= 41–81 |year= 2009 }}

{{United States Congress|powersprivilegesprocedurecommitteeshistoryandmedia}}

Category:Legislative branch of the United States government

Category:Law of the United States

Contempt of Congress

History

Subpoenas

Procedures

= Inherent contempt =

= Statutory proceedings =

= Civil procedures =

Partial list contempt resolutions since 1975

See also

References

External links