Ullmann v. United States

Ullmann clarified the meaning of the privilege against self-incrimination.

On 3 November 1954, William Ludwig Ullmann put in an appearance in the Federal District Court for the Southern District of New York. Ullmann had been subpoenaed to appear before a grand jury that had been convened to investigate espionage and other threats against the federal government. When the grand jury asked him a series of questions about his own or others' activities and Communist Party affiliations, Ullmann refused to answer, citing his Fifth Amendment privilege against self-incrimination.

The U.S. attorney for the district filed an application under the Immunity Act of 1954 for an order requiring Ullmann to testify. The Immunity Act provided witnesses with immunity from criminal prosecution for matters revealed by the compelled testimony. Ullmann in turn challenged the constitutionality of the act, claiming that the so-called "transactional" immunity it afforded would not protect him from other serious harm, such as job loss and social ostracism. The district court upheld the statute and ordered Ullmann to testify. When he again refused to answer questions put to him by a grand jury, he was convicted of contempt of court and sentenced to six months in jail. When his appeal to the Court of Appeals for the Second Circuit failed, Ullmann petitioned the U.S. Supreme Court for review of his case.