[177] United States v. Ballin, 144 U.S. 1, 4 (1892).
[178] Field v. Clark, 143 U.S. 649 (1892); Flint v. Stone Tracy Co., 220 U.S. 107, 143 (1911). A parallel rule holds in the case of a duly authenticated official notice to the Secretary of State that a State legislature has ratified a proposed amendment to the Constitution. Leser v. Garnett, 258 U.S. 130, 137 (1922); see also Coleman v. Miller, 307 U.S. 433 (1939). In Christoffel v. United States, 338 U.S. 84 (1949), a sharply divided Court ruled that, in a case brought under the Perjury Statute of the District of Columbia (§ 22-2501 of the D.C. Code) for alleged perjurious testimony before a Committee of the House of Representatives, the trial Court erred in charging the jury that it was free to ignore testimony that less than a quorum of the Committee was in attendance when the alleged perjury was committed. Four Justices dissented; and curiously enough only four of the majority were present when the opinion was delivered, the fifth being indisposed. Remarks Justice Jackson in his concurring opinion in United States v. Bryan (339 U.S. 323 (1950)), in which the ruling in Christoffel was held to be inapplicable: "It is ironic that this interference with legislative procedures was promulgated by exercise within the Court of the very right of absentee participation denied to Congressmen." Ibid. 344. It seems unlikely that the Christoffel decision seriously undermines Field v. Clark.
[179] Page v. United States, 127 U.S. 67 (1888).
[180] Long v. Ansell, 293 U.S. 76 (1934).
[181] Ibid. 83.
[182] United States v. Cooper, 4 Dall. 341 (1800).
[183] Williamson v. United States, 207 U.S. 425, 446 (1908).
[184] Kilbourn v. Thompson, 103 U.S. 168 (1881).
[185] Ibid.
[186] 4 Mass. 1 (1808).