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United States v. Guest

Intent To Interfere

The United States appealed directly to the Supreme Court under the Criminal Appeals Act. The Court ruled that it did not have jurisdiction to decide the issue of interference with the right to use public accommodations because of a defect in pleading.

Regarding the district court's claim of "indefiniteness," Justice Stewart noted in his opinion that "inclusion of Fourteenth Amendment rights within the compass of 18 U.S.C. sec. 241 does not render the statute unconstitutionally vague." Because the charge is one of conspiracy, the requirement that the offender must have had the intent to interfere with federal rights is satisfied.

Contrary to the argument of the litigants, the indictment contained an allegation of state involvement. This related to the charge of "causing the arrest of Negroes by means of false reports." This allegation was sufficient to prevent this part of the indictment from being dismissed.

The fourth part of the indictment dealt with conspiracy to prevent free travel from and to Georgia and to prevent the use of highway facilities and other instrumentalities of interstate commerce within Georgia. The Supreme Court ruled that the district court should not have dismissed this part of the indictment because the right of interstate travel is protected by 18 U.S.C. sec. 241. However, a specific intent to interfere with this federal right must be proved.

Justice Clark noted in his concurrence that the specific language of sec. 5 of the Fourteenth Amendment "empowers the Congress to enact laws punishing all conspiracies--with or without state action--that interfere with Fourteenth Amendment rights." In other words, Congress has the power to outlaw private conspiracies that violate civil rights.

Additional topics

Law Library - American Law and Legal InformationNotable Trials and Court Cases - 1963 to 1972United States v. Guest - Significance, Intent To Interfere, The Right To Travel, Impact, Related Cases, Burden Of Proof