Claims had been made final. The Gordon decision had indicated
that the Supreme Court could not review the decision of any legislative
court.

[19] 117 U.S. 697, 703. This last doctrine was repeated to the extent
that for many years an award of execution as distinguished from finality
of judgment came to be regarded as an essential attribute of judicial
power. _See_ In re Sanborn, 148 U.S. 222, 226 (1893); Interstate
Commerce Commission _v._ Brimson, 154 U.S. 447, 483 (1894); La Abra
Silver Mining Co. _v._ United States, 175 U.S. 423, 457 (1899); Frasch
_v._ Moore, 211 U.S. 1 (1908); Muskrat _v._ United States, 219 U.S. 346,
355, 361-362 (1911), and Postum Cereal Co. _v._ California Fig Nut Co.,
272 U.S. 693 (1927).

[20] 273 U.S. 70 (1927).

[21] 276 U.S. 71 (1928).

[22] 274 U.S. 123 (1927). This case also clarified any doubts concerning
a federal declaratory judgment act which was passed in 1934 and
sustained in Aetna Life Insurance Co. _v._ Haworth, 300 U.S. 227 (1937).

[23] 288 U.S. 249 (1933). The decision in the Swope and Wallace cases
removed all constitutional doubts which had previously shrouded a
proposed federal declaratory judgment act which was enacted in 1934 (48
Stat. 955) and sustained in Aetna Life Ins. Co. _v._ Haworth, 300 U.S.
227 (1937).

[24] John Charles Fox, The King _v._ Almon, 24 Law Quarterly Review 184,
194-195 (1908).

[25] John Charles Fox, The Summary Power to Punish Contempt, 25 Law
Quarterly Review, 238, 252 (1909).

[26] 1 Stat. 73, 83.

[27] Act of March 2, 1831, 4 Stat. 487, now 18 U.S.C.A. 401. For a
summary of the Peck Impeachment and the background of the act of 1831,
_see_ Felix Frankfurter and James Landis, Power of Congress Over
Procedure in Criminal Contempts in Inferior Federal Courts--A Study in
Separation of Powers, 37 Harvard Law Review, 1010, 1024-1028 (1924).

[28] 19 Wall. 505 (1874).

[29] Ibid. 505, 510-511.

[30] Gompers _v._ Bucks Stove & Range Co., 221 U.S. 418, 450 (1911).
_See also_ In re Debs, 158 U.S. 504, 595 (1895).

[31] U.S. 42 (1924).

[32] 38 Stat. 730 (1914).

[33] 266 U.S. 42, 65-66.

[34] 247 U.S. 402 (1918).

[35] Ibid. 418-421.

[36] 263 U.S. 255 (1923). In his dissent in this case, Justice Holmes
stated that unless a judge has power to "lay hold of anyone who ventures
to publish anything that tends to make him unpopular or to belittle him
* * *. A man cannot be summarily laid by the heels because his words may
make public