say something explicitly it is unconstitutional to infer what it should, might, or could have said. Judicial review means that the Supreme Court can nullify a Congressional law. It is a huge check by the courts on the legislative authority and limits Congressional power substantially. In 1857, for example, the Supreme Court struck down provisions of a Congressional act of 1820 in its Dred Scott decision. At the same time, the Supreme Court can extend Congressional power through its constitutional interpretations. The Congressional inquiry into St. Clair's Defeat of 1791 was the first Congressional investigation of the executive branch. Investigations are conducted to gather information on the need for future legislation, to test the effectiveness of laws already passed, and to inquire into the qualifications and performance of members and officials of the other branches. Committees may hold hearings, and, if necessary, subpoena people to testify when investigating issues over which it has the power to legislate. Witnesses who refuse to testify may be cited for contempt of Congress, and those who testify falsely may be charged with perjury. Most committee hearings are open to the public (the House and Senate intelligence committees are the exception); important hearings are widely reported in the mass media and transcripts published a few months afterwards. Congress, in the course of studying possible laws and investigating matters, generates an incredible amount of information in various forms, and can be described as a publisher. Indeed, it publishes House and Senate reports and maintains databases which are updated irregularly with publications in a variety of electronic formats. Congress also plays a role in presidential elections. Both Houses meet in joint session on the sixth day of January following a presidential election to count the electoral votes, and there are procedures to follow if no candidate wins a majority. The main result of Congressional activity is the creation of laws, most of which are contained in the United States Code, arranged by subject matter alphabetically under fifty title headings to present the laws "in a concise and usable form". Structure Congress is split into two chambersHouse and Senateand manages the task of writing national legislation by dividing work into separate committees which specialize in different areas. Some members of Congress are elected by their peers to be officers of these committees. Further, Congress has ancillary organizations such as the Government Accountability Office and the Library of Congress