Watkins v. United States (1957)

John Watkins was convicted for refusing to answer questions of the House Un-American Activities Committee (HUAC) about people he believed were no longer members of the Communist Party. He asked the Supreme Court to review his conviction after it was affirmed by the Court of Appeals.

In a 6-1 decision, with two justices not participating, the Supreme Court held that the congressional subcommittee had not given Watkins a fair opportunity to determine whether he could lawfully refuse to answer questions, and that his conviction for “contempt of Congress” was therefore invalid under the Fifth Amendment's Due Process Clause.

Chief Justice Earl Warren wrote for the majority: “The power of the Congress to conduct investigations is inherent in the legislative process…. But, broad as is this power of inquiry, it is not unlimited. There is no general authority to expose the private affairs of individuals without justification in terms of the functions of the Congress. …Investigations conducted solely for the personal aggrandizement of the investigators or to 'punish' those investigated are indefensible.”

Justice Thomas Clark dissented. He argued that the majority opinion did not appreciate the actual way in which congressional committees operated. He concluded that Watkins was properly questioned about matters that were legitimately within the scope of the subcommittee's topics. “So long as the object of a legislative inquiry is legitimate and the questions propounded are pertinent thereto, it is not for the courts to interfere with the committee system of inquiry. To hold otherwise would be an infringement on the power given the Congress to inform itself, and thus a trespass upon the fundamental American principle of separation of powers.”

The rise of the House Un-American Activities Committee (HUAC) also gave rise to more cases involving contempt of Congress citations. As Chief Justice Warren described in Watkins: “In the decade following World War II, there appeared a new kind of congressional inquiry unknown in prior periods of American history. Principally this was the result of the various investigations into the threat of subversion of the United States Government…. This new phase of legislative inquiry involved a broad-scale intrusion into the lives and affairs of private citizens.…It was during this period that the Fifth Amendment privilege against self-incrimination was frequently invoked and recognized as a legal limit upon the authority of a committee to require that a witness answer its questions.”

Although Watkins appeared to check the power of HUAC, Justice William O. Douglas later wrote in his autobiography that “the promise contained in the Watkins opinion was not kept. [Other cases] gave the House Un-American Activities Committee broad powers to probe a person's ideas and beliefs. In effect, they allowed the committee to subpoena anyone who had criticized the committee, and to examine all facets of his life, holding him up as a subversive or a traitor and, if he was man enough to defy the committee, to see that he went off to jail for his contempt.”