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Law School Case Brief

United States v. Guest - 383 U.S. 745, 86 S. Ct. 1170 (1966)

Rule:

Not every criminal conspiracy affecting an individual's right of free interstate passage is within the sanction of 18 U.S.C.S. § 241. A specific intent to interfere with the federal right must be proved, and at a trial the defendants are entitled to a jury instruction phrased in those terms. If the predominant purpose of the conspiracy is to impede or prevent the exercise of the right of interstate travel, or to oppress a person because of his exercise of that right, then, whether or not motivated by racial discrimination, the conspiracy becomes a proper object of § 241.

Facts:

Appellees, six private individuals, were indicted under 18 U.S.C.S. § 241 for conspiring to deprive African-American citizens in the vicinity of Athens, Georgia, of the free exercise and enjoyment of rights secured to them by the Constitution and laws of the United States, viz., the right to use state facilities without discrimination on the basis of race, the right freely to engage in interstate travel, and the right to equal enjoyment of privately owned places of public accommodation, now guaranteed by Title II of the Civil Rights Act of 1964. The indictment specified various means by which the objects of the conspiracy would be achieved, including causing the arrest of Negroes by means of false reports of their criminal acts. The district court dismissed the indictment on the ground that it did not involve rights that were attributes of national citizenship, to which it deemed § 241 solely applicable. The district court also held the public-accommodation allegation legally inadequate for failure to allege discriminatory motivation, which the district court thought essential to charge an interference with a right secured by Title II, and because the enforcement remedies in Title II were deemed exclusive. The United States appealed directly to the United States Supreme Court under the Criminal Appeals Act.

Issue:

Was the allegation in the indictment of state involvement in the criminal conspiracy charged under 18 U.S.C.S. § 241 sufficient to charge a violation of rights protected by the Fourteenth Amendment?

Answer:

Yes.

Conclusion:

The United States Supreme Court held that the allegation in the indictment of state involvement in the conspiracy charged under 18 U.S.C.S. § 241 was sufficient to charge a violation of rights protected by the Fourteenth Amendment. The Court held that the indictment contained an express allegation of state involvement sufficient at least to require the denial of a motion to dismiss. The Court found that a criminal conspiracy affecting an individual's right of free interstate passage was within the sanction of § 241, where a specific intent to have interfered with a federal right was required to be proven.

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