United States v. Price

Background

Eighteen people, including a county sheriff, a deputy sheriff, a city patrolman, and several private citizens, were indicted after three men — Michael Schwerner, James Earl Chaney, and Andrew Goodman — were taken from custody, intercepted, assaulted, and killed in Mississippi. The federal indictments charged violations of two Reconstruction-era criminal laws that prohibit conspiracies to injure civil rights and willful deprivations of rights under color of law. The lower court dismissed some counts against the private defendants and dismissed the conspiracy charge against all.

Reasoning

The main question was whether those two federal statutes reach killings and deprivations of life by persons acting with state officers. The Court said yes. It explained that the statutes’ plain words and their history during Reconstruction show they were meant to protect rights under the entire Constitution, including the Fourteenth Amendment. The Justices held that private citizens who join a joint venture with state officials act under color of law and can be prosecuted under the statutes. The Court reversed the dismissals and ordered the cases back for trial.

Real world impact

The decision lets federal prosecutors try people, whether officials or private citizens, when state officers participate in conspiracies that deprive persons of life without due process. It confirms that the federal conspiracy law covers Fourteenth Amendment rights. The ruling resolves a statutory question and does not resolve guilt; defendants must face trial in the lower court.

Dissents or concurrances

Justice Black agreed with the judgment but noted exceptions concerning the Court’s reliance on earlier Williams decisions.