[z] A congressional committee investigating possible complicity of former Attorney General Daugherty in the Teapot Dome scandal subpoenaed records from his brother, Mally, who refused to provide them, alleging Congress had no power to obtain documents from him. Van Devanter ruled for a unanimous court against him, finding that Congress had the authority to conduct investigations as an auxiliary to its legislative function.[199]

Individual and civil rights
In 1925, the Taft Court laid the groundwork for the incorporation of many of the guarantees of the Bill of Rights to be applied against the states through the Fourteenth Amendment. In Gitlow v. New York,[aa] the Court, by a 6–2 vote with Taft in the majority, upheld Gitlow's conviction on criminal anarchy charges for advocating the overthrow of the government; his defense was freedom of speech. Justice Edward T. Sanford wrote the Court's opinion, and both majority and minority (Holmes, joined by Brandeis) assumed that the First Amendment's Free Speech and Free Press clauses were protected against infringement by the states.[200]
Pierce v. Society of Sisters[ab] was a 1925 decision by the Taft Court striking down an Oregon law banning private schools. 