Barenblatt v. United States
Barenblatt v. United States is a pivotal Supreme Court case centered on the tension between congressional investigative powers and individual First Amendment rights. The case arose when Lloyd Barenblatt, a college professor, refused to answer questions regarding his political beliefs before the House Un-American Activities Committee, claiming that such inquiries infringed on his right to free expression. Instead of invoking the Fifth Amendment, Barenblatt argued that the questions violated his First Amendment rights. The Supreme Court ultimately ruled in favor of Congress, emphasizing the public interest in uncovering potential communist subversion during a politically charged era. The decision reflected a balancing of interests, where the need for congressional oversight was deemed more significant than Barenblatt's claim to free expression. The ruling, which was upheld in subsequent cases, highlighted the complexities of navigating individual rights in the face of governmental authority. Overall, Barenblatt v. United States remains a significant legal precedent in discussions about the limits of congressional inquiries and the protection of civil liberties.
Barenblatt v. United States
Date: June 8, 1959
Citation: 360 U.S. 109
Issues: Congressional power of investigation; freedom of association
Significance: The Supreme Court upheld a conviction for contempt of Congress, ruling that the public’s interest in opposing communist infiltration outweighed a person’s limited First Amendment right to refuse to answer questions.
When Lloyd Barenblatt, a college professor, appeared before the House Un-American Activities Committee, he refused to answer questions that dealt with his political beliefs and associations. Rather than relying on the Fifth Amendment, he alleged that the questions infringed on his right to free expression under the First Amendment. The Supreme Court had appeared to give some support to such a claim in Watkins v. United States (1957). Barenblatt was convicted of contempt of Congress.
Speaking for a 5-4 majority, Justice John M. Harlan II used a balancing of interests approach. Although Harlan acknowledged that the First Amendment in some circumstances protects a person “from being compelled to disclose his associational relationships,” he concluded that Barenblatt’s particular claim was outweighed by the public’s interest in exposing communist subversion. In contrast to the situation in Watkins, Harlan found that the subcommittee had explained the relevance of the questions and had not attempted to pillory witnesses. The Barenblatt decision was never overruled. In Eastland v. United States Servicemen’s Club (1975), the Court strengthened the prerogatives of congressional committees by expansively reading the speech or debate clause. When dealing with state investigations, on the other hand, the Court has tended to demonstrate greater concern for protecting First Amendment values.