Kilbourn v. Thompson
Kilbourn v. Thompson is a significant Supreme Court case that addresses the limits of Congressional investigative powers. The case involved the Supreme Court's unanimous opinion, written by Justice Samuel F. Miller, which established that Congress can conduct investigations solely for the purpose of informing future legislation, rather than for judicial or punitive reasons. In this instance, the Court found the Congressional actions to subpoena Hallett Kilbourn and imprison him for contempt improper, highlighting the need for a defined purpose behind legislative inquiries. Over time, subsequent decisions by the Court expanded the understanding of Congressional authority, permitting penalties for contempt and broadening the scope of legislative investigations. This case is often referenced in discussions about the balance between legislative power and individual rights, illustrating the evolving nature of Congressional authority in the U.S. legal framework. Understanding Kilbourn v. Thompson is crucial for anyone exploring the historical context of Congressional investigations and the legal boundaries that define them.
Kilbourn v. Thompson
Date: 1881
Citation: 103 U.S. 168
Issues: Contempt of Congress; congressional power of investigation
Significance: The Supreme Court declared that Congress’s investigative power and its derivative contempt power were limited to legislative not judicial purposes.
Justice Samuel F. Miller wrote the unanimous opinion of the Supreme Court in this undated decision, holding that Congress may conduct investigations to obtain information only for future legislation and not for judicial purposes. For this reason, the congressional attempt to subpoena Hallett Kilbourn, hold him in contempt, and imprison him were improper. In later decisions, the Court did allow for punishment for contempt of Congress and also allowed a broader definition of the scope of legislative investigation.
