United States v. Robel
United States v. Robel is a significant Supreme Court case from 1967 that addressed the constitutionality of the Subversive Activities Control Act of 1950. This act required individuals associated with groups deemed subversive, including the Communist Party, to register with the government. The case arose when Robel, a member of the Communist Party, was indicted for employment at a shipyard involved in national defense. The Supreme Court, in a 6-2 decision, ultimately overturned Robel's conviction, highlighting that the law did not differentiate between active and passive members of subversive organizations. Chief Justice Earl Warren argued that the statute was overly broad and could lead to convictions based solely on association, thus infringing on constitutional protections for free speech and assembly. This ruling effectively diminished the authority of the Subversive Activities Control Board, although it did not directly overturn a related case from 1961. Dissenting opinions were presented by Justices Byron R. White and John Marshall Harlan, while Justice Thurgood Marshall did not participate in the decision. The case reflects key tensions in U.S. law regarding civil liberties and national security during the Cold War era.
United States v. Robel
Date: December 11, 1967
Citation: 389 U.S. 258
Issues: Freedom of speech; freedom of association
Significance: The Supreme Court, in a rare move, struck a congressional enactment for violating the First Amendment.
The 1950 Subversive Activities Control Act required members of allegedly subversive organizations, such as the Communist Party, to register with the Subversive Activities Control Board. Communist Party member Robel was indicted for working at a shipyard involved in the defense industry. By a 6-2 vote, the Supreme Court overturned Robel’s conviction and a section of the act. The Court argued that because the act made no distinction between active and passive members of allegedly subversive organizations, people could be found guilty by association. Chief Justice Earl Warren, in the opinion for the Court, found that the statute was overbroad in the activities it prohibited. This decision did not directly overturn Communist Party v. Subversive Activities Control Board (1961), but its practical effect was to render the board a nullity. Justices Byron R. White and John Marshall Harlan dissented. Justice Thurgood Marshall did not participate.
