[3] The first was that no candidate for Congress shall, in procuring his nomination and election, spend any sum in excess of the amount provided for by state law.

Truman Handy Newberry was a Michigan businessman and former Secretary of the Navy who decided to run for the U.S. Senate as a Republican in 1918.

Ford challenged Newberry and used his federal connections to win an investigation by Congress and the United States Department of Justice.

Writing for the majority, Justice James Clark McReynolds held that the U.S. Constitution did not grant Congress the power to regulate primary elections or political party nomination processes.

The Seventeenth Amendment, promulgated in May 1913, neither instituted nor required a new meaning of the term "election" and so did not modify Article I, Section 4.

Moreover, Congress does not need to regulate primaries and nomination procedures in order to effectively perform its duties under Article I, Section 4.

Chief Justice White, dissenting but concurring with a modification in the judgment of reversal, found no constitutional infirmity.