Watkins v. United States
Annotate this Case
354 U.S. 178 (1957)
U.S. Supreme Court
Watkins v. United States, 354 U.S. 178 (1957)
Watkins v. United States
Argued March 7, 1957
Decided June 17, 1957
354 U.S. 178
Petitioner was convicted of a violation of 2 U.S.C. § 192, which makes it a misdemeanor for any person summoned as a witness by either House of Congress or any committee thereof to refuse to answer any question "pertinent to the question under inquiry." Summoned to testify before a Subcommittee of the House of Representatives Committee on Un-American Activities, petitioner testified freely about his own activities and associations, but he refused to answer questions as to whether he had known certain other persons to have been members of the Communist Party. He based his refusal on the ground that those questions were outside of the proper scope of the Committee's activities, and not relevant to its work. No clear understanding of the "question under inquiry" could be gleaned from the resolution authorizing the full Committee, the legislative history thereof, the Committee's practices thereunder, the action authorizing the Subcommittee, the statement of the Chairman at the opening of the hearings or his statement in response to petitioner's protest.
Held: Petitioner was not accorded a fair opportunity to determine whether he was within his rights in refusing to answer, and his conviction was invalid under the Due Process Clause of the Fifth Amendment. Pp. 354 U. S. 181-216.
(a) The power of Congress to conduct investigations, inherent in the legislative process, is broad, but it is not unlimited. P. 354 U. S. 187.
(b) Congress has no general authority to expose the private affairs of individuals without justification in terms of the functions of Congress. P. 354 U. S. 187.
(c) No inquiry is an end in itself; it must be related to, and in furtherance of, a legitimate task of Congress. P. 354 U. S. 187.
(d) The Bill of Rights is applicable to congressional investigations, as it is to all forms of governmental action. P. 354 U. S. 188.
(e) A congressional investigation is subject to the command that Congress shall make no law abridging freedom of speech or press or assembly. Pp. 354 U. S. 196-197.
(g) A congressional investigation into individual affairs is invalid if unrelated to any legislative purpose, because it is beyond the powers conferred upon Congress by the Constitution. Kilbourn v. Thompson, 103 U. S. 168. P. 354 U. S. 198.
(h) It cannot simply be assumed that every congressional investigation is justified by a public need that overbalances any private rights affected, since to do so would be to abdicate the responsibility placed by the Constitution upon the judiciary to insure that Congress does not unjustifiably encroach upon an individual's right of privacy nor abridge his liberty of speech, press, religion or assembly. Pp. 354 U. S. 198-199.
(i) There is no congressional power to expose for the sake of exposure where the predominant result can be only an invasion of the private rights of individuals. P. 354 U. S. 200.
(j) In authorizing an investigation by a committee, it is essential that the Senate or House should spell out the committee's jurisdiction and purpose with sufficient particularity to insure that compulsory process is used only in furtherance of a legislative purpose. P. 354 U. S. 201.
(k) The resolution authorizing the Un-American Activities Committee does not satisfy this requirement, especially when read in the light of the practices of the Committee and subsequent actions of the House of Representatives extending the life of the Committee. Pp. 354 U. S. 201-205.
(l) Every reasonable indulgence of legality must be accorded to the actions of a coordinate branch of our Government, but such deference cannot yield to an unnecessary and unreasonable dissipation of precious constitutional freedoms. P. 354 U. S. 204.
(m) Protected freedoms should not be placed in danger in the absence of a clear determination by the House or Senate that a particular inquiry is justified by specific legislative need. P. 354 U. S. 205.
(n) Congressional investigating committees are restricted to the missions delegated to them -- to acquire certain data to be used by the House or Senate in coping with a problem that falls within its legislative sphere -- and no witness can be compelled to make disclosures on matters outside that area. P. 354 U. S. 206.
(o) When the definition of jurisdictional pertinency is as uncertain and wavering as in the case of the Un-American Activities Committee, it becomes extremely difficult for the Committee to limit its inquiries to statutory pertinency. P. 354 U. S. 206.
(p) The courts must accord to a defendant indicted under 2 U.S.C. § 192 every right which is guaranteed to defendants in all other criminal cases, including the right to have available information revealing the standard of criminality before the commission of the alleged offense. Pp. 354 U. S. 207-208.
(q) Since the statute defines the crime as refusal to answer "any question pertinent to the question under inquiry," part of the standard of criminality is the pertinency of the questions propounded to the witness. P. 354 U. S. 208.
(r) Due process requires that a witness before a congressional investigating committee should not be compelled to decide, at peril of criminal prosecution, whether to answer questions propounded to him without first knowing the "question under inquiry" with the same degree of explicitness and clarity that the Due Process Clause requires in the expression of any element of a criminal offense. Sinclair v. United States, 279 U. S. 263. Pp. 354 U. S. 208-209.
(s) The authorizing resolution, the remarks of the chairman or members of the committee, or even the nature of the proceedings themselves, might make the "question under inquiry" sufficiently clear to avoid the "vice of vagueness"; but these sources often leave the matter in grave doubt. P. 354 U. S. 209.
(t) In this case, it is not necessary to pass on the question whether the authorizing resolution defines the "question under inquiry" with sufficient clarity, since the Government does not contend that it could serve that purpose. P. 354 U. S. 209.
(u) The opening statement of the Chairman at the outset of the hearings here involved is insufficient to serve that purpose, since it merely paraphrased the authorizing resolution, and gave a very general sketch of the past efforts of the Committee. Pp. 354 U. S. 209-210.
(v) Nor was that purpose served by the action of the full Committee in authorizing the creation of the Subcommittee before which petitioner appeared, since it merely authorized the Chairman to appoint subcommittees "for the purpose of performing any and all acts which the Committee as a whole is authorized to do." Pp. 354 U. S. 211-212.
(w) On the record in this case, especially in view of the precise questions petitioner was charged with refusing to answer, it cannot
be said that the "question under inquiry" was Communist infiltration into labor unions. Pp. 354 U. S. 212-214.
(x) Unless the subject matter of the inquiry has been made to appear with undisputable clarity, it is the duty of the investigative body, upon objection of the witness on grounds of pertinency, to state for the record the subject under inquiry at that time and the manner in which the propounded questions are pertinent thereto. Pp. 354 U. S. 214-215.
(y) The Chairman's response, when petitioner objected to the questions on grounds of pertinency, was inadequate to convey sufficient information as to the pertinency of the questions to the "question under inquiry." Pp. 354 U. S. 214-215.
98 U.S.App.D.C.190, 233 F.2d 681, reversed and remanded.
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