Blair v. United States

Background

Several people, including Blair, Templeton, and Phillips, were subpoenaed in Michigan to appear before a federal grand jury in New York investigating alleged violations tied to reports about a Michigan primary for U.S. Senator. Each appeared, was sworn, and then left a written statement refusing to answer questions. They said the Corrupt Practices Act was unconstitutional and that federal courts and grand juries had no authority to investigate primary elections. After a hearing, the district court ordered them to answer; they again refused, were held in contempt, committed to the marshal’s custody, sought habeas relief, and had that relief denied before these appeals and writs of error reached the Court.

Reasoning

The Court explained that, as a general rule, persons summoned as witnesses have a duty to attend and answer questions before a grand jury. Historical practice and federal statutes recognize the grand jury’s power to investigate and to require witnesses to testify. The Court said witnesses are not entitled to challenge the grand jury’s subject-matter or the constitutionality of the statute under inquiry merely by refusing to answer. Although the Fifth Amendment protects against self-incrimination, no valid claim of that protection was made here; ordinary objections about relevance or jurisdiction are not for a summoned witness to decide. The Court therefore affirmed the contempt judgments and commitments.

Real world impact

The decision means people called to testify before a federal grand jury cannot block questioning simply by declaring the law under investigation unconstitutional or outside the grand jury’s power. The ruling affirms the use of contempt and custody to enforce testimony. The Court did not decide whether the Corrupt Practices Act itself is constitutional, leaving that question for proper parties and later proceedings.