Yates v. United States Case Brief

Why is the case important?

Fourteen individuals were arrested, and later convicted by a trial court, for violation Smith Act. These individuals were accused of advocating, teaching and intending to overthrow the government.

Facts of the case

Fourteen leaders of the Communist Party in the state of California were tried and convicted under the Smith Act. That Act prohibited willfully and knowingly conspiring to teach and advocate the overthrow of the government by force. This case was decided in conjunction with Richmond v. United States and Schneiderman v. United States .

Question

Whether the Smith Act, in violation of the First and Fourteenth Amendment rights of free speech and assembly, prohibits advocacy and teaching of forcible overthrow as an abstract principle, divorce from any effort to instigate action to that end so long as such advocacy or teaching is engaged in with evil intent?

Answer

No. The Smith Act does not violate the First and Fourteenth Amendments of the Constitution, as it does not punish mere advocacy and teaching of forcible overthrow as an abstract principle. The Smith Act does not punish mere doctrinal justification of forcible overthrow, unless it is engaged with the intent to accomplish overthrow. The Court states that the Smith Act does not denounce advocacy in the sense of preaching abstractly the forcible overthrow of the government. Furthermore, the trial court’s statement that the proscribed advocacy must include the urging, necessity and duty of forcible overthrow, and not merely its desirability and propriety, may not be regarded as a sufficient substitute for charging that the Smith Act reaches only advocacy of action for the overthrow of government by force and violence. The essential distinction is that those to whom the advocacy is addressed must be urged to do something, now or in the future, rather than to merely believe in somethi
ng. Therefore, as the Smith Act requires more than just the mere teaching of beliefs in order to be held in violation of the act, i.e. some overt action or the advocacy of immediate violent action, the act does not violate the First and Fourteenth Amendments of the United States Constitution.

Conclusion

Defendant Yates and his crew caught undersized red grouper in federal waters in the Gulf of Mexico in violation of the federal conservation regulations. A federal officer boarded the vessel and noticed that the red grouper fish appeared to be smaller than the requisite 20 inches. The officer informed defendant that the fish shall be seized upon the vessel’s return port. To prevent confirmation that the fish were undersized, defendant instructed his crew to throw the fish overboard and replace them with larger fish. As a result, defendant was charged with destruction and falsification of evidence under 18 U.S.C.S. § 1519 and was eventually found guilty by both the district court and the U.S. Court of Appeals.

  • Case Brief: 1957
  • Petitioner: John L. Yates
  • Respondent: United States
  • Decided by: Roberts Court

Citation: 574 US 528 (2015)
Granted Apr 28, 2014
Argued: Nov 5, 2014
Decided: Feb 25, 2015