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Watkins v. United States - Further Readings

Petitioner
John T. Watkins
Respondent
United States
Petitioner's Claim
That Congress does not have unlimited power to investigate the private livesof individual citizens.
Chief Lawyer for Petitioner
Joseph L. Rauh, Jr.
Chief Lawyer for Respondent
J. Lee Rankin, U. S. Solicitor General
Justices for the Court
Hugo Lafayette Black, William J. Brennan, Jr., William O. Douglas, Felix Frankfurter, John Marshall Harlan II, Earl Warren (writing for the Court)
Justices Dissenting
Tom C. Clark (Harold Burton and Charles Evans Whittaker did not participate)
Place
Washington, D.C.
Date of Decision
17 June 1957
Decision
The Supreme Court ruled that the congressional power of investigation is notunlimited and should not intrude upon law enforcement, a function of the executive branch, or try cases, thus assuming a judicial role.
Significance
Watkins was one of the decisions in favor of persons accused of communist affiliations handed down on "Red Monday" by the liberal Court headed by Chief Justice Warren. These decisions signaled a change not only in the attitude of the Supreme Court, but an abatement of the anti-communist hysteria thathad gripped the nation since the end of the Second World War.
The House Un-American Activities Committee (HUAC) was first established in 1938 for the purpose of investigating Nazi, fascist, communist and other "un-American" organizations. In 1945, towards the end of World War II, it was givenpermanent status. HUAC reached the pinnacle of its power in the early 1950s,during a period known as the Red Scare, when Senator Joseph McCarthy of Wisconsin, playing on fears generated by Soviet post-war expansionism, whipped uppublic hysteria about an international communist conspiracy. McCarthy and HUAC became notorious, however, for their attempts to unmask domestic communists. McCarthy was eventually discredited in 1954, and by the time the Supreme Court decided Watkins, paranoia about communist infiltration had quieted somewhat.
John T. Watkins was a labor union official. His name had been mentioned by two witnesses who appeared earlier before HUAC and agreed to "name names" of others with allegedly communist affiliations. Both witnesses claimed that Watkins had recruited them into the Communist Party in 1943. Watkins himself testified that he had never been a member of the Communist Party, but that from 1942 to 1947, he had cooperated with the party and made contributions to communist causes. He agreed to answer any questions the committee might have abouthim and any others he knew to be Communist Party members. Watkins declined, however, to answer questions about individuals who, although they might have been party members in past, no longer held that status.
Watkins was convicted of contempt of Congress, and this conviction was affirmed by the Court of Appeals for the District of Columbia. Watkins then petitioned the U.S. Supreme Court for review of this decision.
Supreme Court Rules that Congressional Power of Investigation Is Not Unlimited
Watkins was one of four decisions the Court handed down in what came to known as "Red Monday." In all four, the Court ruled against governmental attempts to prosecute alleged communists. Watkins was especially significant because of the limits it placed on Congress's power to investigate individual citizens. Writing for the Court, Chief Justice Warren clearly indicatedthat HUAC had overstepped its bounds:
[B]road as is this [congressional] power of investigation, it is not unlimited. There is no general authority to expose the private affairs of individuals without justification in terms of the functions of the Congress . . . Nor is the Congress a law enforcement or trial agency. These are functions of the executive and judicial departments of government. No inquiry is an end in itself; it must be related to,and in furtherance of the Congress.

For good measure, Warren included a reprimand to those legislators, like Senator McCarthy, who were manipulating people's lives--as well as the public's fears--to advance their own political careers: "Investigations conducted solely for the personal aggrandizement of the investigators or to `punish' those investigated are indefensible."
The Red Monday decisions caused a revolt among conservative legislators. Onesenator, William Jenner, even introduced a bill to take away the Court's power to hear cases involving alleged subversives. Facing such protest, two members of the Court, Justices Frankfurter and Harlan, retreated from their previous stance. In various cases heard over the next three years, there were enough votes to uphold convictions of Communist Party members. This reversal did not last long, however. With the retirement of Frankfurter in 1962, the WarrenCourt resumed its liberal posture.
Related Cases

  • Kilbourn v. Thompson, 103 U.S. 168 (1881).
  • American Communications Association v. Douds, 339 U.S. 382 (1950).

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