United States v. Guest

The Supreme Court clarified when the federal law against conspiracy can be used in a case involving interference in the right to travel freely between states. The purpose of the conspiracy must be to impede or prevent interstate travel or to oppress a person exercising that right. Then, whether or not racial discrimination is the motivation, the conspiracy falls under the federal conspiracy law.

Lyndon B. Johnson became president of the United States in November 1963, upon the assassination of President John F. Kennedy. As a memorial to the slain president, Johnson proposed to Congress that it act on a civil rights bill. The Civil Rights Act of 1964 increased federal powers to give access to all races to public facilities, to protect voting rights, and to desegregate schools. Title II of this act made it a federal offense to discriminate against any customer in a place of public accommodation. Six months later, the U.S. Supreme Court decided that the Commerce Clause could be used to bar private discrimination. The Commerce Clause is part of the Constitution that grants to Congress the power to regulate commerce. Freedom marches and riots marked the era when blacks fought for their civil rights. United States v. Guest took place against the backdrop of the burgeoning Civil Rights Movement.

Six men were accused of conspiring to injure, oppress, threaten, and intimidate black citizens in Athens, Georgia, beginning in 1964. The men were indicted by a U.S. grand jury in the Middle District of Georgia. They were indicted under 18 U.S.C. Sec. 241, a federal law dealing with conspiracy, for conspiring to deprive black citizens of the free exercise and enjoyment of rights secured by the Constitution and laws of the United States. In particular, the indictment noted the right to use state facilities without discrimination by race, the right freely to engage in interstate travel, and the right to equal enjoyment of privately owned places of public accommodation. These rights had recently been guaranteed by Title II of the Civil Rights Act of 1964. The indictment listed how the accused had conspired to deprive blacks of their rights: shooting, beating, killing, damaging or destroying property, pursuing and threatening with guns, making threatening phone calls, wearing disguises on the highway and premises of others, causing the arrest of blacks by making false reports, and burning crosses at night in public view.

The district court dismissed the indictment against the men on the grounds that it did not involve rights which are attributes of national citizenship. The district court, regarding the right to equal use of public facilities that are owned or operated by the state of Georgia, ruled that 18 U.S.C. 241 did not encompass any Fourteenth Amendment rights. The Fourteenth Amendment guarantees equal protection. The court also decided that any broader interpretation of sec. 241 would "render it void for indefiniteness." The district court further held that the Equal Protection Clause does not apply to private action, but only to state action. The court claimed that the public-accommodation allegation was inadequate because it did not show that discrimination was the motivation.