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Watkins v. United States Legal Brief

Watkins v. United States (1957)
354 U.S. 178; 77 S.Ct. 1173; 1 L.Ed. 2d 1273
Vote 6-1

The Facts of the case are these: “John Watkins was subpoenaed to testify before the House Committee on Un-American Activities. After answering the committee’s questions about his past association with the Communist Party, Watkins refused to say whether certain other named individuals were members of the party. Watkins protested the committee’s questions, saying, ‘I do not believe that such questions are relevant to the work of this committee nor do I believe that this committee has the right to undertake the public exposure of persons because of their past activities.’ For his refusal to cooperate, Watkins was convicted of contempt of Congress.”

The Issues in this case are these: 1. Does Congress have the authority to compel a person to testify? 2. Does Congress have the authority to compel a person to testify against another person? 3. Does Congress have the authority to convict a person for refusal or “contempt of Congress”?

The Holding in this case is this: 1. Does Congress have the authority to compel a person to testify? Yes, to a point… 2. Does Congress have the authority to compel a person to testify against another person? Yes, to a point… “There is no general authority to expose the private affairs of individuals without justification in terms of the functions of the Congress…” 3. Does Congress have the authority to convict a person for refusal or “contempt of Congress?” Yes, to a point… “It is unquestionably the duty of all citizens to cooperate with the Congress in its efforts to obtain the facts needed for intelligent legislative action. It is their unremitting obligation to respond to subpoenas, to respect the dignity of the Congress and its committees and to testify fully with respect to matters within the province of property investigation. This, of course, assumes that the constitutional rights of witnesses will be respected by the Congress as they are in a court of justice.

The Majority Opinion written by the Chief Justice Warren finds that “The Bill of Rights is applicable to investigations as to all forms of governmental action. Witness cannot be compelled to give evidence against themselves. They cannot be subjected to unreasonable search and seizure. Nor can the First Amendment freedoms of speech, press, religion, or political belief and association be abridged…. The Government contends that the public interest at the core of the investigations of the Un-American Activities Committee is the need by the Congress to be informed of efforts to overthrow the Government by force and violence so that adequate legislative safeguards can be erected. From this core, however, the Committee can radiate outward infinitely to any topic thought to be related in some way to armed insurrection. The outer reaches of this domain are known only by the content of ‘un-American activities.’ It is, of course, not the function of this Court to prescribe rigid rules for the Congress to follow in drafting resolutions establishing investigating committees…. ….Watkins was not accorded a fair opportunity to determine whether he was within his rights in refusing to answer, and his conviction is necessarily invalid under the Due Process Clause of the Fifth Amendment.”

Mr. Justice Burton and Mr. Justice Whittaker took no part in the consideration or decision of this case.

Mr. Justice Frankfurther wrote a separate opinion concurring with the Majority.

Mr. Justice Clark wrote a separate opinion dissenting, he stated: “As I see it the chief fault in the majority opinion is its mischievous curbing of the informing function of the Congress. While I am not versed in its procedures, my experience in the executive branch of the government leads me to believe that the requirements laid down in the opinion for the operation of the committee system of inquiry are both unnecessary and unworkable…. The majority has substituted the judiciary as the grand inquisitor and supervisor or congressional investigations. It has never been so….”

The significance of this case is that the Court affirmed that like in court, a person has a right to be free from compulsion to testify against themselves. It also indicated that Congress had to make a witness aware of such rights.

Citation: American Constitutional Law: Sources of Power and Restraint, Congress and the Development of National Power

Legal Brief by David A.W. Hittle
May 2, 2013