United States v. Guest - Impact

United States v. Guest has been cited in many cases dealing with the right of interstate travel. It has been used to show that the constitutional right of interstate travel is a fundamental right. In a 1993 case, Jayne Bray, et al., Petitioners v. Alexandria Women's Health Clinic et al., involving a woman's right to travel interstate to reach an abortion clinic, the opinion cited United States v. Guest. The respondents in the abortion clinic case relied upon the right to interstate travel, which in at least some contexts, is a right constitutionally protected against private interference. But all that the clinic noted with respect to that particular right was the district court's finding that many women seeking the services of the clinics in the Washington Metropolitan area travel on the interstate to get there. "That is not enough," noted the opinion. Quoting United States v. Guest: Only "if the predominant purpose of the conspiracy is to impede or prevent the exercise of the right of interstate travel, or to oppress a person because of his exercise of that right, then . . . the conspiracy becomes a proper object of the federal conspiracy law."