Watkins v. United States

Last updated
Watkins v. United States
Seal of the United States Supreme Court.svg
Argued March 7, 1957
Decided June 17, 1957
Full case nameJohn Watkins v. United States
Citations 354 U.S. 178 ( more )
77 S. Ct. 1173; 1 L. Ed. 2d 1273; 1957 U.S. LEXIS 1558; 76 Ohio L. Abs. 225
Prior history Cert. to the United States Court of Appeals for the District of Columbia Circuit
Watkins was unable to determine his obligation to respond to questions posed to him and so was denied due process.
Court membership
Chief Justice
Earl Warren
Associate Justices
Hugo Black  · Felix Frankfurter
William O. Douglas  · Harold H. Burton
Tom C. Clark  · John M. Harlan II
William J. Brennan Jr.  · Charles E. Whittaker
Case opinions
Majority Warren, joined by Black, Frankfurter, Douglas, Harlan, Brennan
Concurrence Frankfurter
Dissent Clark
Burton, Whittaker took no part in the consideration or decision of the case.

Watkins v. United States, 354 U.S. 178 (1957), is a decision of the Supreme Court of the United States that held that the power of the United States Congress is not unlimited in conducting investigations and that nothing in the US Constitution gives it the authority to expose individuals' private affairs.

Supreme Court of the United States Highest court in the United States

The Supreme Court of the United States (SCOTUS) is the highest court in the federal judiciary of the United States. Established pursuant to Article III of the U.S. Constitution in 1789, it has original jurisdiction over a narrow range of cases, including suits between two or more states and those involving ambassadors. It also has ultimate appellate jurisdiction over all federal court and state court cases that involve a point of federal constitutional or statutory law. The Court has the power of judicial review, the ability to invalidate a statute for violating a provision of the Constitution or an executive act for being unlawful. However, it may act only within the context of a case in an area of law over which it has jurisdiction. The court may decide cases having political overtones, but it has ruled that it does not have power to decide nonjusticiable political questions.

United States Congress Legislature of the United States

The United States Congress is the bicameral legislature of the Federal Government of the United States. The legislature consists of two chambers: the House of Representatives and the Senate.



John Thomas Watkins, a labor union official from Rock Island, Illinois, was convicted of contempt of Congress, a misdemeanor under 2 U.S.C.   § 192, for failing to answer questions posed by members of Congress during a hearing held by a subcommittee of the House of Representatives Committee on Un-American Activities on April 29, 1954.

Rock Island, Illinois Place in Illinois, United States

Rock Island is a city in and the county seat of Rock Island County, Illinois, United States. The original Rock Island, from which the city name is derived, is the largest island on the Mississippi River. It is now called Arsenal Island. The population was 39,018 at the 2010 census. Located on the Mississippi River, it is one of the Quad Cities, along with neighboring Moline, East Moline, and the Iowa cities of Davenport and Bettendorf. The Quad Cities has a population of about 380,000. The city is home to Rock Island Arsenal, the largest government-owned weapons manufacturing arsenal in the US, which employs 6,000 people.

Title 2 of the United States Code outlines the role of Congress in the United States Code.

House Un-American Activities Committee Investigative committee of the US House of Representatives during the Red Scare

The House Un-American Activities Committee was an investigative committee of the United States House of Representatives. The HUAC was created in 1938 to investigate alleged disloyalty and subversive activities on the part of private citizens, public employees, and those organizations suspected of having Fascist or Communist ties. In 1969, the House changed the committee's name to "House Committee on Internal Security". When the House abolished the committee in 1975, its functions were transferred to the House Judiciary Committee.

Watkins was born in July 1910 and ended his formal education in the eighth grade. At the time of his testimony he had four children and was working on behalf of the United Auto Workers (UAW) to unionize workers at a division of Firestone Tire and Rubber in Illinois. The UAW underwrote his legal expenses. [1]

Firestone Tire and Rubber Company is an American tire company founded by Harvey Firestone in 1900 initially to supply solid rubber side-wire tires for fire apparatus, and later, pneumatic tires for wagons, buggies, and other forms of wheeled transportation common in the era. Firestone soon saw the huge potential for marketing tires for automobiles, and the company was a pioneer in the mass production of tires. Harvey Firestone had a personal friendship with Henry Ford, and used this to become the original equipment supplier of Ford Motor Company automobiles, and was also active in the replacement market.

Watkins was asked to name people he knew to be members of the Communist Party. Watkins told the subcommittee that he did not wish to answer such questions and that they were outside the scope of the subjects on which he was summoned to testify and of the committee's jurisdiction. He said: [2]

Communist Party USA American political party

The Communist Party USA, officially the Communist Party of the United States of America (CPUSA), is a communist party in the United States established in 1919 after a split in the Socialist Party of America following the Russian Revolution.

I am not going to plead the fifth amendment, but I refuse to answer certain questions that I believe are outside the proper scope of your committee's activities. I will answer any questions which this committee puts to me about myself. I will also answer questions about those persons whom I knew to be members of the Communist Party and whom I believe still are. I will not, however, answer any questions with respect to others with whom I associated in the past. I do not believe that any law in this country requires me to testify about persons who may in the past have been Communist Party members or otherwise engaged in Communist Party activity but who to my best knowledge and belief have long since removed themselves from the Communist movement.

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. I may be wrong, and the committee may have this power, but until and unless a court of law so holds and directs me to answer, I most firmly refuse to discuss the political activities of my past associates.

His conviction carried a fine of $100 and a one-year suspended prison sentence. Watkins first won a 3–2 decision on appeal to the US Court of Appeals for the District of Columbia [3] but then lost, 6–2, when that court heard the case en banc. [4] The Supreme Court heard arguments on March 7, 1957 and announced its decision on June 17, 1957.


The Supreme Court decided 6-1 to overturn Watkins' conviction. Chief Justice Earl Warren wrote for the majority. [2] Warren noted that it is an offense for a witness to refuse to answer any question "pertinent to the question under inquiry" in testifying before a Congressional committee, but he wrote that the Court was unable to ascertain the nature of the Congressional inquiry with reasonable precision:

There are several sources that can outline the "question under inquiry" in such a way that the rules against vagueness are satisfied. The authorizing resolution, the remarks of the chairman or members of the committee, or even the nature of the proceedings themselves, might sometimes make the topic clear. This case demonstrates, however, that these sources often leave the matter in grave doubt.

The New York Times commented: "The Supreme Court has placed fundamental restrictions on a Congressional investigatory power that in recent years has been asserted as all but limitless." [5]

Senators James Eastland and William E. Jenner, who played principal roles in investigating left-wing activities, issued a statement accusing the Court of contributing to "the trend of the past year of undermining our existent barriers against Communist subversion." [5]

The decision's impact was limited in that the Court limited the application of the principles it espoused in Watkins. [6] [ clarification needed ]

See also

Related Research Articles

Abington School District v. Schempp, 374 U.S. 203 (1963), was a United States Supreme Court case in which the Court decided 8–1 in favor of the respondent, Edward Schempp legal responsible of his son Ellery Schempp, and declared school-sponsored Bible reading in public schools in the United States to be unconstitutional. The Chief Justice of the Supreme Court during this case was Earl Warren.

Executive privilege is the power of the President of the United States and other members of the executive branch of the United States Government to resist certain subpoenas and other interventions by the legislative and judicial branches of government in pursuit of information or personnel relating to the executive. The power of Congress or the federal courts to obtain such information is not mentioned explicitly in the United States Constitution, nor is there any explicit mention in the Constitution of an executive privilege to resist such requests from Congress or courts. The Supreme Court of the United States has ruled this privilege may qualify as an element of the separation of powers doctrine, derived from the supremacy of the executive branch in its own area of Constitutional activity.

Contempt of Congress is the act of obstructing the work of the United States Congress or one of its committees. Historically, the bribery of a U.S. Senator or U.S. Representative was considered contempt of Congress. In modern times, contempt of Congress has generally applied to the refusal to comply with a subpoena issued by a Congressional committee or subcommittee—usually seeking to compel either testimony or the production of requested documents.

Yates v. United States, 354 U.S. 298 (1957), was a case decided by the Supreme Court of the United States that held that the First Amendment protected radical and reactionary speech, unless it posed a "clear and present danger."

Nathan Witt Lawyer, former Secretary of the U.S. National Labor Relations Board

Nathan Witt, born Nathan Wittowsky, was an American lawyer who is best known as being the Secretary of the National Labor Relations Board (NLRB) from 1937 to 1940. He resigned from the NLRB after his communist political beliefs were exposed and he was accused of manipulating the Board's policies to favor his own political leanings. He was also investigated several times in the late 1940s and 1950s for being a spy for the Soviet Union in the 1930s. No evidence of espionage was ever found.

Congressional oversight is oversight by the United States Congress over the Executive Branch, including the numerous U.S. federal agencies. Congressional oversight includes the review, monitoring, and supervision of federal agencies, programs, activities, and policy implementation. Congress exercises this power largely through its congressional committee system. Oversight also occurs in a wide variety of congressional activities and contexts. These include authorization, appropriations, investigative, and legislative hearings by standing committees; specialized investigations by select committees; and reviews and studies by congressional support agencies and staff.

Kilbourn v. Thompson, 103 U.S. 168 (1880), was a United States Supreme Court case that dealt with the question whether or not the United States House of Representatives may compel testimony.

Speech or Debate Clause

The Speech or Debate Clause is a clause in the United States Constitution. The clause states that members of both Houses of Congress

...shall in all Cases, except Treason, Felony and Breach of the Peace, be privileged from Arrest during their attendance at the Session of their Respective Houses, and in going to and from the same; and for any Speech or Debate in either House, they shall not be questioned in any other Place.

Fifth Amendment to the United States Constitution Amendment guaranteeing rights related to trials and due process

The Fifth Amendment to the United States Constitution addresses criminal procedure and other aspects of the Constitution. It was ratified in 1791 as part of the Bill of Rights. The Fifth Amendment applies to every level of the government, including the federal, state, and local levels, as well as any corporation, private enterprise, group, or individual, or any foreign government in regards to a US citizen or resident of the US. The Supreme Court furthered the protections of this amendment through the Due Process Clause of the Fourteenth Amendment.

Malloy v. Hogan, 378 U.S. 1 (1964), was a case in which the Supreme Court of the United States deemed defendants' Fifth Amendment privilege not to be compelled to be witnesses against themselves was applicable within state courts as well as federal courts, overruling the decision in Twining v. New Jersey (1908). The majority decision holds that the Fourteenth Amendment allows the federal government to enforce the first eight amendments on state governments.

Wilkinson v. United States, 365 U.S. 399 (1961), was a court case during the McCarthy Era in which the petitioner, Frank Wilkinson, an administrator with the Los Angeles Public Housing Authority, challenged his conviction under 2 U.S.C. § 192, which makes it a misdemeanor to refuse to answer any question pertinent to the question under inquiry for any person summoned as a witness by Congress. The petitioner's conviction was sustained in a 5-4 ruling, upholding a prior ruling in Barenblatt v. United States.

Barenblatt v. United States, 360 U.S. 109 (1959), was a case in which the Supreme Court of the United States ruled that the actions of the House Un-American Activities Committee did not violate the First Amendment and, thus, the Court upheld Barenblatt's conviction for contempt of Congress. The Court held that the congressional committee had authority to compel a college professor to answer questions about his Communist Party membership.

Neri vs. Senate Committee, et al. is a controversial ruling of the Supreme Court of the Philippines which affirmed the invocation of executive privilege by petitioner Romulo Neri, member of the Cabinet of President Gloria Macapagal-Arroyo, regarding questions asked during a Congressional inquiry on the controversial multimillion-dollar National Broadband Network (NBN) Project. The Supreme Court finally affirmed this ruling on September 4 and 23, 2008 by denying the defendant Senate Committees' first and second Motions for Reconsideration.

The United States Senate Select Committee on Improper Activities in Labor and Management was a select committee created by the United States Senate on January 30, 1957, and dissolved on March 31, 1960. The select committee was directed to study the extent of criminal or other improper practices in the field of labor-management relations or in groups of employees or employers, and to suggest changes in the laws of the United States that would provide protection against such practices or activities. It conducted 253 active investigations, served 8,000 subpoenas for witnesses and documents, held 270 days of hearings, took testimony from 1,526 witnesses, and compiled almost 150,000 pages of testimony. At the peak of its activity in 1958, 104 persons worked for the committee. The select committee's work led directly to the enactment of the Labor-Management Reporting and Disclosure Act on September 14, 1959.

Scull v. Virginia ex rel. Committee on Law Reform and Racial Activities, 359 U.S. 344 (1959), is a 9-to-0 ruling by the Supreme Court of the United States which held that a conviction violates the Due Process Clause of the Fourteenth Amendment to the United States Constitution if the defendant is not given an opportunity "to determine whether he was within his rights in refusing to answer" an inquiry put to him by the legislature of a U.S. state.

United States v. Alfonso D. Lopez, Jr., 514 U.S. 549 (1995), was the first United States Supreme Court case since 1937 to hold that Congress exceeded its power under the Commerce Clause of the United States Constitution. The Supreme Court held that the federal Gun-Free School Zones Act of 1990, which banned possession of handguns near schools, was unconstitutional because it did not have a substantial impact on interstate commerce. After the Lopez decision, the act was amended to specifically only apply to guns that had been moved via interstate commerce.

Smith Act trials of Communist Party leaders

The Smith Act trials of Communist Party leaders in New York City from 1949 to 1958 were the result of US federal government prosecutions in the postwar period and during the Cold War between the Soviet Union and the United States. Leaders of the Communist Party of the United States (CPUSA) were accused of violating the Smith Act, a statute that prohibited advocating violent overthrow of the government. The defendants argued that they advocated a peaceful transition to socialism, and that the First Amendment's guarantee of freedom of speech and of association protected their membership in a political party. Appeals from these trials reached the US Supreme Court, which ruled on issues in Dennis v. United States (1951) and Yates v. United States (1957).

Scales v. United States, 367 U.S. 203 (1961), was a 1960 decision of the United States Supreme Court that upheld the conviction of Junius Scales for violating of the Smith Act on the basis on his membership in the Communist Party of the United States (CPUSA).

Noto v. United States, 367 U.S. 290 (1961), was a 1961 United States Supreme Court case that reversed the felony conviction of a lower-echelon official of the Communist Party USA (CPUSA).

Sweezy v. New Hampshire, 354 U.S. 234 (1957), was a case before the United States Supreme Court in which the Court ruled that jailing an academic when he refused to answer questions about university lectures he had given was a violation of due process. On a larger scale, the decision established constitutional protections for academic freedom and reined in the investigative powers of state legislatures.


  1. New York Times: "Court Ends his Dilemma," June 18, 1957, accessed June 16, 2012
  2. 1 2 FindLaw: John Watkins v. United States 354 U.S. 178 (1957)
  3. New York Times: Luther A. Huston, "U.S. Court Upsets Contempt Ruling," January 27, 1956, accessed June 16, 2012
  4. New York Times: Luther A. Huston, "Red Cases Lead High Court's List," October 9, 1956, accessed June 16, 201
  5. 1 2 New York Times: "Inquiry Reform Seen Inevitable," June 19, 1957, accessed June 16, 2012
  6. Arthur J. Sabin, In Calmer Times: The Supreme Court and Red Monday (University of Pennsylvania Press, 1999), 156