WATKINS v. UNITED STATES

Facts of the Case

Petitioner, a union officer appearing as a witness before a subcommittee of the House Committee on Un-American Activities, refused to answer questions as to past Communist Party membership of certain persons, objecting to the questions on the ground of lack of pertinency to the subject under inquiry by the subcommittee. In a prosecution in the United States District Court for the District of Columbia, he was convicted of violating 2 U.S.C. § 192, the statute providing for criminal punishment of witnesses before congressional committees who refused to answer any question pertinent to the question under inquiry, and the conviction was affirmed by the United States Court of Appeals for the District of Columbia Circuit.

Question

Did the activities of the Un-American Activities Committee constitute an unconstitutional exercise of congressional power?

CONCLUSION

In a 6-to-1 decision, the Court held that the activities of the House Committee were beyond the scope of congressional power. The Court held that both the authorizing resolution of the Committee and the specific statements made by the Committee to Watkins failed to limit the Committee’s power. The Court found that because Watkins had not been given sufficient information describing the pertinency of the questions to the subjects under inquiry, he had not been accorded a fair opportunity to determine whether he was within his rights in refusing to answer. The Due Process Clause of the Fifth Amendment thus invalidated Watkins’ conviction.

Case Information

  • Citation: 354 US 178 (1957)
  • Argued: Mar 7, 1957
  • Decided Jun 17, 1957