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United States v. Guest, 383 U.S. 745 (1966), is a United States Supreme Court opinion, authored by Justice Potter Stewart, in which the court extended the protection of the 14th Amendment to citizens who suffer rights deprivations at the hands of private conspiracies, where there is minimal state participation in the conspiracy. The Court also held that there is Constitutional right to travel from state to state.

United States v. Guest
Seal of the United States Supreme Court
Argued November 9, 1965
Decided March 28, 1966
Full case nameUnited States v. Guest
Citations383 U.S. 745 (more)
86 S. Ct. 1170; 16 L. Ed. 2d 239
Case history
Prior246 F. Supp. 475 (M.D. Ga. 1964) (reversed and remanded)
Court membership
Chief Justice
Earl Warren
Associate Justices
Hugo Black · William O. Douglas
Tom C. Clark · John M. Harlan II
William J. Brennan Jr. · Potter Stewart
Byron White · Abe Fortas
Case opinions
MajorityStewart, joined by Black, Clark, White, Fortas; Harlan (in part); Warren, Douglas, Brennan (in part)
ConcurrenceClark, joined by Black, Fortas
Concur/dissentHarlan
Concur/dissentBrennan, joined by Warren, Douglas
Laws applied
U.S. Const. amend. XIV; Civil Rights Act of 1964

Justice Stewart, writing for the majority, held that "there now can be no doubt that the specific language of §5 empowers the Congress to enact laws punishing all conspiracies - with or without state action - that interfere with 14th Amendment rights," wrote Justice Tom C. Clark in a concurring opinion. Justice Hugo Black and Justice Abe Fortas joined Clark's concurrence.

Contents

BackgroundEdit

The case arose out of the killing of Lemuel Penn, an African-American reserve officer who was returning from active duty to Washington, D.C., where he was a school teacher. He was travelling north with several friends in a car when he was shot on a bridge, just nine days after the Civil Rights Act of 1964 passed.

The murder happened in Madison County, Georgia, and the alleged killers were charged but acquitted there by an all-white jury. The federal indictment in question arose after the acquittal. In District Court, the six defendants successfully "moved to dismiss the indictment on the ground that it did not charge an offense under the laws of the United States," according to the case. The Supreme Court reversed.

The argument revolved around whether or not Congress intended to apply equal protection rights of the 14th Amendment to citizens deprived of said rights on public facilities—i.e. roads and bridges or interstate commerce facilities—by private actors with the collusion of public actors, in this case police who responded to the murderers' false reports that Penn and his cohorts had committed crimes.

Opinion of the CourtEdit

The question was whether or not 18 U.S.C. §241 of the Criminal Code could be applied to protect the rights of equal protection and due process secured by the Fourteenth Amendment to the United States Constitution. The Court held that it could.

Concurrence/dissentsEdit

Justice William Brennan, Chief Justice Earl Warren and Justice William O. Douglas concurred in part and dissented in part.

Brennan wrote: "(I) believe that §241 reaches such a private conspiracy, not because the 14th Amendment of its own force prohibits such a conspiracy, but because §241, as an exercise of congressional power under §5 of that Amendment, prohibits all conspiracies to interfere with the exercise of a 'right (secured) by the Constitution.'"

See alsoEdit

Further readingEdit

  • Belknap, Michal R. (1982). "The Legal Legacy of Lemuel Penn". Howard Law Journal. 25: 457–524.

External linksEdit