Whether the D.C. Circuit's interpretation of "willfully" in 2 U.S.C. § 192 to require only intentional conduct, rather than knowledge of unlawfulness, is correct, and whether the proper composition of a congressional committee bears on its authority to issue a subpoena.

Whether the criminal statute 2 U.S.C. § 192 requires more than mere intentional conduct to prove the mens rea element of 'willfully' when a congressional subpoena recipient is prosecuted for non-compliance