<P> In Anderson v. Dunn (1821), 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 ." 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 which made "contempt of Congress" a criminal offense against the United States . </P> <P> The last time Congress arrested and detained a witness was in 1935 . Since then, it has instead referred cases to the United States Department of Justice . The Office of Legal Counsel has asserted that the President of the United States is protected from contempt by executive privilege . </P> <P> 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 . </P> <P> As announced in Wilkinson v. United States, 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 . </P>

Who has the power to issue a subpoena