The third type of contempt power—Congress’s dormant inherent contempt power—is rarely used in modern times. Inherent contempt was the mode employed by Congress to directly enforce contempt rulings under its own constitutional authority until criminal and civil contempt statutes were passed, and it remained in use into the twentieth century. Under inherent contempt proceedings, the House or Senate has its Sergeant-At-Arms, or deputy, take a person into custody for proceedings to be held in Congress.

Although these powers are not directly stated in the Constitution, the Supreme Court has ruled on multiple occasions that they are implicit as an essential legislative power held by Congress.

Justice Willis Van Devanter made perhaps the most famous statement of these powers in McGrain v. Daugherty, a 1927 Supreme Court decision about Mally S. Daugherty, the brother of former Attorney General Harry Daugherty. A select Senate committee issued a subpoena for Daugherty to testify and to also surrender records from an Ohio bank. When Daugherty refused to comply after a second subpoena, the Senate passed a resolution issuing a warrant and authorizing a Senate deputy to take Daugherty into custody. Daugherty filed a habeas petition against his detention. A lower court ruled that the Senate exceeded its powers by detaining Daugherty, freeing him. However, the Supreme Court upheld his conviction, holding that under the Constitution, Congress has the power to compel witnesses and testimony “to obtain information in aid of the legislative function.”

https://constitutioncenter.org/blog/the-houses-contempt-powers-explained