Endicott Johnson Corp. v. Perkins (317 U.S. 501 (1943)) was a follow up to Crowell v. Benson (285 U.S. 22 (1932)), and applied the notion of ultra vires to subpoena powers. In the case, Johnson resisted a subpoena because they felt that the Administrative Agency was acting outside their jurisdiction.

  • The Court found that the information in the subpoena was necessary for the agency to determine where their jurisdictional limits were.
  • Basically, an agency can conduct an inquiry to determine their jurisdiction, even if it later turns out that the people getting subpoenaed were outside of the agency’s jurisdiction.