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In Sinclair v. United States (1929), the Supreme Court ruled that Congress had a right to investigate anything related to its legislative and oversight duties, including Harry Sinclair’s personal dealings with the Secretary of the Interior. In an earlier Teapot Dome case, McGrain v. Daugherty (1927), it ruled that congressional committees could compel private citizens to testify.
Records of the Supreme Court of the United States, National Archives and Records Administration