Watkins v. United States

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 indicated that 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. One senator, 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 Warren Court resumed its liberal posture.