United States v. Williams (1951)

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United States v. Williams
Seal of the United States Supreme Court.svg
Argued January 8, 1951
Decided April 23, 1951
Full case nameUnited States v. Jay G. Williams et al.
Citations 341 U.S. 70 ( more )
71 S. Ct. 581; 95 L. Ed. 758
Prior historyWilliams v. United States, 179 F.2d 644 (5th Cir. 1950)
Holding
An allegation where individuals acted under color of State law in an indictment under § 241 does not extend the protection of the section to rights which the Federal Constitution merely guarantees against abridgment by the States. (affirming 5th Circuit)
Court membership
Chief Justice
Fred M. Vinson
Associate Justices
Hugo Black  · Stanley F. Reed
Felix Frankfurter  · William O. Douglas
Robert H. Jackson  · Harold H. Burton
Tom C. Clark  · Sherman Minton
Case opinions
Majority Frankfurter, joined by Vinson, Jackson, Minton
Concurrence Black
Dissent Douglas, joined by Reed, Burton, Clark
Laws applied
18 U.S.C.   § 241

United States v. Williams, 341 U.S. 70 (1951), is a decision by the United States Supreme Court that provides that 18 U.S.C.   § 241 (protecting US citizens' Fourteenth Amendment rights from individuals sworn to uphold laws) may only be applied to federal cases and is not available to the state governments. [1]

Title 18 of the United States Code is the main criminal code of the federal government of the United States. The Title deals with federal crimes and criminal procedure. In its coverage, Title 18 is similar to most U.S. state criminal codes, which typically are referred to by such names as Penal Code, Criminal Code, or Crimes Code. Typical of state criminal codes is the California Penal Code. Many U.S. state criminal codes, unlike the federal Title 18, are based on the Model Penal Code promulgated by the American Law Institute.

Fourteenth Amendment to the United States Constitution which grants citizenship to everyone born in the U.S. and subject to its jurisdiction and protects civil and political liberties

The Fourteenth Amendment to the United States Constitution was adopted on July 9, 1868, as one of the Reconstruction Amendments. Arguably one of the most consequential amendments to this day, the amendment addresses citizenship rights and equal protection of the laws and was proposed in response to issues related to former slaves following the American Civil War. The amendment was bitterly contested, particularly by the states of the defeated Confederacy, which were forced to ratify it in order to regain representation in Congress. The amendment, particularly its first section, is one of the most litigated parts of the Constitution, forming the basis for landmark decisions such as Brown v. Board of Education (1954) regarding racial segregation, Roe v. Wade (1973) regarding abortion, Bush v. Gore (2000) regarding the 2000 presidential election, and Obergefell v. Hodges (2015) regarding same-sex marriage. The amendment limits the actions of all state and local officials, including those acting on behalf of such an official.

Contents

Background

Jay G. Williams [2] was employed by a Florida detective agency. In 1947, the agency was hired by a Florida company to investigate thefts occurring on the company’s property. Williams was the head of the detective agency. Williams, two other employees of the detective agency, and a member of the Miami police force participated in the investigation. As some of the company's employees became suspects; Williams and his collaborators, without arresting the suspects, took them one by one to an isolated building on the company's premises. There the investigators subjected them to intense interrogations which, “after blows, kicks, threats, and prolonged exposure to a brilliant light”, yielded a confession. [1]

Florida State of the United States of America

Florida is the southernmost contiguous state in the United States. The state is bordered to the west by the Gulf of Mexico, to the northwest by Alabama, to the north by Georgia, to the east by the Atlantic Ocean, and to the south by the Straits of Florida. Florida is the 22nd-most extensive, the 3rd-most populous, and the 8th-most densely populated of the U.S. states. Jacksonville is the most populous municipality in the state and the largest city by area in the contiguous United States. The Miami metropolitan area is Florida's most populous urban area. Tallahassee is the state's capital.

Detective investigator, either a member of a police agency or a private person

A detective is an investigator, usually a member of a law enforcement agency. They often collect information to solve crime by talking to witnesses and informants, collecting physical evidence, or searching records in databases. This leads them to arrest criminals and enable them to be convicted in court. A detective may work for the police or privately.

Interrogation interviewing employed by law enforcement officers, military personnel, and intelligence agencies with the goal of eliciting useful information

Interrogation is interviewing as commonly employed by law enforcement officers, military personnel, and intelligence agencies with the goal of eliciting useful information. Interrogation may involve a diverse array of techniques, ranging from developing a rapport with the subject to outright torture.

The conduct of the detective agency fell outside of the scope of activities permitted by Florida law. Thus, Williams and his accomplices were arrested and charged with a federal crime, 18 U. S. C. §§ 241: prohibiting willfully, under color of the laws, statutes, ordinances, regulations and customs of the State of Florida subjecting an inhabitant(s) of the State of Florida, to deprivation of the rights, privileges and immunities secured to him and protected by the Fourteenth Amendment. [3]

18 U. S. C. §§ 241 originated with the Enforcement Act of 1870, which enforced the “Right of Citizens of the United States to vote in the several States of this Union, and for other Purposes." In furtherance of its chief end of assuring the right of African American to vote, it provided that it should be a misdemeanor for any "person or officer" wrongfully to fail in a duty imposed on him by State law to perform or permit performance of acts necessary to registering or voting. In the course of passage through Congress several sections were added which had a larger purpose. One of them was derived from the Civil Rights Act of 1866, and was designed to "secure to all persons the equal protection of the laws." [1]

Enforcement Act of 1870

The Enforcement Act of 1869, also known as the Civil Rights Act of 1870 or First Ku Klux Klan Act, or Force Act was a United States federal law written to empower the President with the legal authority to enforce the first section of the Fifteenth Amendment throughout the United States. The act was the first of three Enforcement Acts passed by the United States Congress from 1870 to 1871 during the Reconstruction Era to combat attacks on the suffrage rights of African Americans from state officials or violent groups like the Ku Klux Klan.

Civil Rights Act of 1866 First U. S. federal law to define citizenship and affirm that all citizens are equally protected by the law

The Civil Rights Act of 1866, 14 Stat. 27–30, enacted April 9, 1866, was the first United States federal law to define citizenship and affirm that all citizens are equally protected by the law. It was mainly intended, in the wake of the American Civil War, to protect the civil rights of persons of African descent born in or brought to the United States. This legislation was passed by Congress in 1865 and vetoed by U.S. President Andrew Johnson. In April 1866 Congress again passed the bill to support the Thirteenth Amendment. Johnson again vetoed it, but a two-thirds majority in each chamber overcame the veto to become law without presidential signature.

Supreme Court Opinion

In a narrow 5-4 vote, the Supreme Court determined that 18 U. S. C. §§ 241 was instituted by the federal courts to prohibit only officers of the federal government from violating constitutional rights. It was determined that the statute did not cover officers of a state who violate the state rights of its citizens. Therefore, it was determined that the federal court did not have jurisdiction to prosecute Williams under 18 U. S. C. §§ 241 because he was under commission by the State of Florida and not by the US Federal Government. [4]

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Eleventh Amendment to the United States Constitution US constitution amendment dealing with each states sovereign immunity

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References

  1. 1 2 3 United States v. Williams, 341 U.S. 70 (1951).
  2. Pastor, James (October 17, 2006). Security Law and Methods. Butterworth-Heinemann. p. 463. ISBN   9780080465937.
  3. Young, Rowland L. (August 1951). "Review of Recent Supreme Court Decisions". American Bar Association Journal. 37 (8): 604–605. JSTOR   25717749.
  4. Hall, Kermit (2000). Freedom and Equality: Discrimination and the Supreme Court. Garland Publishing. p. 218 n.61. ISBN   9780815334309.
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