The United States Constitution vests Congress with broad authority to discipline its Members. Article I, Section 5, clause 2, provides Congress with the power to "...determine the Rules of its Proceedings, punish its Members for disorderly Behaviour, and, with the Concurrence of two thirds, expel a Member." Initially, interpretation and implementation of this clause was reconstituted on a case-by-case basis. When the need arose, both the House of Representatives and the Senate conducted investigations and issued punishments on an ad-hoc basis. As a result, institutional self-discipline was generally inconsistent and sporadic, with neither chamber having systematic definitions of disorderly behavior or codes of conduct to guide disciplinary action. In the Federalist Papers, James Madison discussed concerns over self-discipline. "No man is allowed to be a judge in his own cause, because his interest would certainly bias his judgment, and, not improbably, corrupt his integrity. With equal, nay with greater reason, a body of men are unfit to be both judges and parties at the same time...." While Madison addressed the potential for conflicts of interest to be raised in a legislative environment, the lesson can also be applied to the judgment of ethics-related issues and the trust necessary for effective government. Prior to the creation of the ethics committees in the 1960s, Congress historically was hesitant to use its power to conduct ethics investigations—except for the most grievous offenses. Instead, Congress traditionally relied on "either criminal prosecution or voter rejection at the polls to punish misbehavior by Members." Overall, this was seen as an effective strategy. Until 1957, when Congress adopted the first government-wide code of ethics for government service, the lack of a formal ethics process resulted in Congress following general society's norms of decency and applying sanctions in only the most egregious cases. Former Senate historian Richard Baker observed, "[f]or nearly two centuries, a simple and informal code of behavior existed. Prevailing norms of general decency served as the chief determinants of proper legislative conduct." As a result, Congress chose "to deal, on a case-by-case basis, only with the most obvious acts of wrongdoing, those clearly 'inconsistent with the trust and duty of a member.'" Additionally, there were no ethics cases brought to the floor between the 69 th Congress (1925-1927) and the 89 th Congress (1965-1966). This caused some scholars and interest groups to call for reform of the ethics enforcement process. This led to the creation of the House Committee on Standards of Official Conduct (now the Committee on Ethics) in 1967. The investigation of disciplinary cases—and the recommendation of sanctions, if necessary—have since been under the committee's exclusive jurisdiction. In the majority of instances, once the Ethics Committee has reported a sanction recommendation, it has been ultimately adopted by the House in that form. In some circumstances, however, floor amendments or legislative alternatives have been offered to the committee's recommendation—either to increase or lessen the sanction. The House, however, has never failed to adopt a sanction—either the recommended action or an alternative—following a committee recommendation. Since 1967, the committee has taken action to recommend that the House sanction a Member 16 times. Of these 16 cases, seven (43%) have included attempts to alter the sanction recommendation, and three (42% of the seven cases and 18% of all cases) have been successful. While not a majority of cases, the offering (and sometimes adoption) of an alternate sanction illustrates that altering a sanction recommendation is possible. Between 1789 and 1957, the House dealt with relatively few ethics cases. As standards of acceptable behavior has shifted from one era to the next, House ethics enforcement has evolved. For example, historical ethics cases have included charges of disorderly behavior for spitting or hitting on the House floor, insulting the Speaker of the House, and taking up arms against the United States. Because a standing ethics committee did not exist in the House until 1967, the House investigated these cases by referring them to existing standing committees, creating ad-hoc investigatory committees, or dealing with the case directly on the House floor. The effort to create a formal code of conduct began in the Senate in the late 1940s and early 1950s. In the 85 th Congress (1957-1958), Congress adopted a general Code of Ethics for Government Service to oversee officials and employees in all three branches of government. The standards included in the Code of Ethics for Government Service were the first government-wide ethics provisions and are still recognized as the foundation of the House's and Senate's continuing ethics guidance. The Code of Ethics for Government Service, however, was not legally binding because the code was adopted by congressional resolution, not by public law. Even with the adoption of the Code of Ethics for Government Service, Congress continued to rely on unwritten norms of conduct and the existence of a "club spirit." Pursuant to investigations of the alleged misconduct of a Senate staff member and of Representative Adam Clayton Powell in the 1960s, attention was drawn to the perceived absence of standards for congressional conduct and the ad-hoc approach to congressional self-discipline. In response, in 1964, the Senate created the Select Committee on Standards and Conduct, and in 1967, the House established the Committee on Standards of Official Conduct. In the House, the committee was given the authority to investigate allegations of wrongdoing by Members, officers, and employees in its chamber; to adjudicate evidence of misconduct; to recommend penalties, when appropriate; and to provide advice on actions permissible under congressional rules and law. Additionally, the Ethics Committee has formal jurisdiction over the Code of Official Conduct and Member financial disclosure. The creation of a House ethics committee was "intended by Speaker John McCormack to be noncontroversial." To further this intent, the committee's membership is divided equally between majority and minority, and its investigation and sanction recommendation process is designed to be as bipartisan and objective as possible. To reach this point, however, the committee needed to overcome early concerns about the difficulty of distancing themselves from partisan interests. Serving that purpose, several high-profile investigations were undertaken in the committee's early years against Members of both parties. These included "Abscam," "Koreagate," "Pagegate," "Iraqgate," the House Post Office "check bouncing" scandal, and the House bank scandal. When the need to investigate a House Member, officer, or staffer arises, the Ethics Committee operates pursuant to authorities found in House Rule X, clause 5(a)(4)(A) and (B), and House Rule XI, clause 3. Once the committee decides that an investigation is necessary, a two-step process begins. First, the committee determines whether the allegations have merit. If they do, the committee formally opens an investigation by empaneling an investigatory subcommittee. If the committee determines that the allegations are without merit, the investigation is discontinued. Second, if the investigation concludes that wrongdoing occurred, a Statement of Alleged Violations (formal charges) is sent to the full committee, and an adjudicatory subcommittee is appointed. The adjudicatory subcommittee evaluates the Statement of Alleged Violations and after holding a hearing, recommends sanctions, if warranted. The adjudicatory process ensures that facts are reviewed by the committee and that a "...Statement of Alleged Violation has been proved by clear and convincing evidence." Following the adjudicatory hearing, the subcommittee determines whether the actions specified in the Statement of Alleged Violations warrant further action by the full committee or the House, such as sanctioning the Member. If it is determined that further action is warranted, the subcommittee forwards the findings to the full committee with a recommendation for discipline. The full committee may then vote to approve, disapprove, or alter the subcommittee's recommendation, and report a sanction resolution to the House as appropriate. Historically, the committee has recommended several punishments. These have included expulsion, censure, reprimand, and "Letters of Reproval" or "Letters of Admonition." Since the Ethics Committee was created in 1967, numerous Members have left the House after court convictions, after inquiries were initiated, or after charges were brought by the committee before completion of House action. Regardless of the potential offense, a Member's departure from the House ends a case, as the committee does not have jurisdiction over former Members. A resolution recommending expulsion, censure, or reprimand of a Member presents a question of privilege. If reported by the Ethics Committee pursuant to its duties as listed in House Rule XI, clause 3(q), the resolution may be called up at any time for consideration by the House. The House can then agree to the resolution and accept the recommendation, it may attempt to alter the recommendation, or defeat the resolution and reject the sanction. Expulsion is the only punishment specifically mentioned in Article I of the Constitution. Pursuant to the Article I, Section 5, clause 2, the House has the power to expel a Member, after the Member has taken the oath of office, by a two-thirds vote of those present and voting. Historically, expulsion has been used sparingly. When used, Members have been expelled for offenses related to official conduct or being deemed "unfit to participate in the deliberations and decisions of the House and whose presence in it tends to bring that body into contempt and disgrace." Unlike expulsion, censure is not specifically mentioned in the Constitution. The House, however, derives its censure authority from the same clause in the Constitution because it clearly provides authority for an unspecified range of punishments. As defined by House precedent, censure is a formal vote by the majority of Members present and voting on a resolution disapproving a Member's conduct. Often, the resolution requires the Member to stand in the "well" of the House chamber to receive a verbal rebuke and reading of the censure resolution by the Speaker of the House.