Quinn v. United States

Background

Petitioner was a field representative for the United Electrical, Radio and Machine Workers of America and was subpoenaed to a House Un‑American Activities subcommittee with two other union officers. The committee asked whether they had been members of the Communist Party. Fitzpatrick invoked the First and Fifth Amendments, Panzino referred to the Fifth Amendment, and petitioner adopted Fitzpatrick’s statements. All three were later indicted under 2 U.S.C. § 192 for refusing to answer; Fitzpatrick and Panzino were acquitted, but petitioner was convicted in the District Court and sentenced to jail and a fine.

Reasoning

The Court explained that no special words are required to invoke the Fifth Amendment privilege and that a witness may adopt another witness’s invocation. It held petitioner’s references to the Fifth Amendment were sufficient to notify the committee of an apparent claim. Because the committee never asked him to clarify or indicated it rejected the claim, the record did not show the deliberate, intentional refusal required for conviction under § 192, so the Court reversed and directed acquittal.

Real world impact

The decision protects the right against self‑incrimination in congressional hearings by requiring committees to make clear when they reject a witness’s privilege claim and to give the witness a direct opportunity to answer. It limits contempt prosecutions when a witness’s claim is ambiguous and the committee does not clearly demand an answer.

Dissents or concurrances

Justice Harlan agreed with the result but disagreed with part of the majority’s reasoning on intent. Justice Reed dissented, arguing the witnesses had not adequately apprised the committee they were claiming the Fifth Amendment.