Watkins v. United States (1957)

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Watkins v. United States (1957) is the U.S. Supreme Court case holding that the Due Process Clause of the Fifth Amendment limits Congress’s ability to conduct investigations, namely its ability to require testimony on inquiries unrelated to the charge for which Congress summoned the witness to testify. Find a full opinion here.

In response to the Red Scare of the early-1950s, the House of Representatives created the Committee on Un-American Activities to investigate links, real or perceived, to the Communist Party. The Committee issued a subpoena to John Watkins, who worked as a labor union organizer, to appear as a witness to clarify allegations that he was a member of the Communist Party. Watkins denied allegations that he was a member of the Communist Party to the Committee’s satisfaction, but the Committee then inquired into other persons whom Watkins knew and whom the Committee believed to be communists. Watkins refused to answer the Committee’s roving inquiry on persons he knew, objecting that “I [do not] believe that this committee has the right to undertake the public exposure of persons because of their past activities.” The Committee initiated a prosecution to hold him in contempt and the Court of Appeals of the District of Columbia upheld his conviction of one year in prison and a $100 fine for contempt. Watkins appealed to the U.S. Supreme Court and they granted certiorari. 

The U.S. Supreme Court, in a 6–1 opinion written by Chief Justice Warren, overturned the conviction, finding that Congress’s roving inquiry violated Watkins’ procedural due process rights of the Fifth Amendment. The Court conceded that a witness could be held in contempt for refusing to answer a Congressional Committee’s questions that carries out a specific legislative task. However, the Court reasoned, jurisdictionally a Committee only has the power to inquire into matters pertinent to the legislative task delegated to them. 

Here, the Court noted, the Committee’s task was vague and unclear. The Court emphasized this, stating, “[i]t would be difficult to imagine a less explicit authorizing resolution.” The Court even criticized the Committee members for having clearly demonstrated “that they did not feel themselves restricted in any way to propaganda in the narrow sense of the word.” In Watkins’ case, when he questioned the pertinence of the questions on other persons he knew, the Committee responded that the question under inquiry was “subversion and subversive propaganda.” The Court found this “at least as broad and indefinite as the authorizing resolution of the Committee, if not more so.” Thus, the Court concluded that the Committee failed to “convey sufficient information as to the pertinency of the questions to the subject under inquiry.” By doing so, the Committee violated Watkins’ fair opportunity to determine whether he was within his rights in refusing, rendering his conviction in violation of the Fifth Amendment. 

[Last updated in April of 2021 by the Wex Definitions Team]