Ullman v. United States

Date: March 26, 1956

Citation: 350 U.S. 42

Issues: Immunity against self-incrimination; congressional power of investigation

Significance: The Supreme Court refused to protect those given limited immunity from prosecution in exchange for their testimony before a grand jury investigating communist activities.

Justice Felix Frankfurter wrote the opinion for the 7-2 majority, upholding the Immunity Act. A federal court acting under the Immunity Act ordered defendant Ullman to testify before a grand jury investigating communist activities that potentially endangered national security. Despite having transactional immunity from state or federal prosecution for his compelled testimony, Ullman refused to testify and was imprisoned for six months for contempt of court. On appeal, Ullman said the immunity was incomplete because he still faced potential loss of a job or union membership and public contempt. Frankfurter rejected the argument, pointing out that the Fifth Amendment protected only against criminal prosecution. Justices Hugo L. Black and William O. Douglas dissented.

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