United States v. Price
The Supreme Court revived federal criminal charges against 18 men, including three Mississippi law-enforcement officers, accused in the 1964 killings of civil rights workers Michael Schwerner, James Chaney, and Andrew Goodman. The Court ruled that private citizens who conspire with government officials to deprive someone of constitutional rights can be prosecuted right alongside those officials, and that a key federal civil-rights conspiracy law fully covers violations of the Fourteenth Amendment's promise of due process.
The ruling reversed a lower court that had thrown out charges against the non-official defendants and had ruled one of the two statutes could never reach Fourteenth Amendment violations at all. By reading both statutes broadly, the Court strengthened the federal government's ability to prosecute private violence carried out in partnership with state officials.
“It is enough that he is a willful participant in joint activity with the State or its agents.”
Explains when a private citizen counts as acting 'under color of law' alongside government officials.
How it got here: A federal district court in Mississippi dismissed parts of both indictments, and the government's direct appeal brought the statutory questions straight to the Supreme Court.
The Case in Depth
What happened
In June 1964, a Neshoba County, Mississippi deputy sheriff arrested three civil rights workers, released them at night, then intercepted and helped kill them along with other law-enforcement officers and private citizens. A federal grand jury indicted 18 people under two Reconstruction-era civil rights statutes for conspiring to and actually depriving the three men of their constitutional right to due process of law.
The question before the Court
Could federal prosecutors use Reconstruction-era civil rights laws to charge private citizens — not just police officers — who teamed up with a sheriff's deputy to murder three civil rights workers in Mississippi?
The Court's answer
Yes — private citizens who conspire with government officials to violate someone's constitutional rights can be prosecuted under these federal civil rights laws right alongside the officials. The Court ruled that acting "under color of law" doesn't require being an officer yourself; it's enough to willfully join in a scheme carried out with state officials, because their participation makes the whole venture official action.
The Court also ruled that the broader federal conspiracy statute at issue plainly covers conspiracies to violate Fourteenth Amendment due-process rights, rejecting a narrower reading that had limited it to rights flowing directly from federal power. Both dismissed sets of charges against the private defendants and the officers were reinstated and sent back for trial.
Curious how the Court got there? See the step-by-step legal reasoning →
Why it matters
This ruling gave federal prosecutors a clear path to charge private individuals — not just officers — whenever they act jointly with police or other state officials to violate someone's constitutional rights. It became a foundational tool for federal civil-rights prosecutions in cases where local authorities were unwilling or complicit, including many prosecutions that followed in the decades after this case.
What changes now
Both indictments are reinstated as to the previously dismissed counts and sent back to the trial court, where the 18 defendants will face prosecution under both federal statutes. This is a final resolution of the statutory questions — the case is not an emergency or temporary order — though the defendants' guilt or innocence still must be determined at trial.
What this does not decide
The Court decided only whether the federal statutes could reach this conduct as a matter of statutory interpretation — not whether the defendants were actually guilty, and not any broader constitutional question about the scope of federal power, which the Court said was already well established.
Concurrences and dissents
Concurrence in part — Justice Black
Justice Black agreed with the judgment and most of the Court's reasoning but declined to join the parts of the opinion that relied on the three prior 'Williams' decisions from 1951. He did not explain his specific objection to those cases in the text provided, but limited his agreement to exclude reliance on them.
How the Court got there
The legal reasoning, step by step
- For the substantive counts under 18 U.S.C. § 242, the Court asked what it means to act 'under color of law' — the requirement that someone be connected to government authority before this statute applies.
- The Court held that a private person does not need to be a government officer to act 'under color of law'; it is enough that he willfully participates in joint activity with a state official, because the state's involvement taints the whole joint venture with official authority.
- Applying that rule to the facts, the Court found that because a sheriff's deputy released the three men from jail and officers took part in every stage of the plan, the private citizens who joined that scheme were also acting under color of law and could be charged as principals.
- Turning to the conspiracy charges under 18 U.S.C. § 241, the Court examined the statute's plain text, which bars conspiring to interfere with any right secured by the Constitution or federal law, without any listed exceptions.
- The Court rejected an earlier, narrower reading (from a four-justice opinion in a prior case that never became binding precedent because the Court had divided evenly) that would have limited the statute to rights flowing directly from federal power rather than rights protected against state interference, such as due process under the Fourteenth Amendment.
- Reviewing the statute's history from Reconstruction, including a Senate sponsor's floor remarks, the Court concluded that Congress intended the statute to reach conspiracies against Fourteenth Amendment rights carried out by officials, private individuals, or both acting together.
Doctrinal impact
Cases affected by this decision
Reaffirms Screws v. United States (325 U. S. 91)
The Court relies on this case as settled law that willfully denying due process under color of law violates § 242.
Distinguishes Williams I (341 U. S. 70)
The Court explains this earlier case never resolved the statute's scope because the Justices split evenly, leaving the question open.