United States v. Harris

Supreme Court of the United States
106 U.S. 629, 1 S. Ct. 601, 1882 U.S. LEXIS 1595 (1883)

ELI5:

Rule of Law:

Congress's legislative power under the Fourteenth Amendment is limited to remedying state action that violates the amendment's provisions; it does not extend to regulating the purely private conduct of individuals. Furthermore, congressional power under the Thirteenth Amendment is confined to eradicating slavery and its badges and incidents, and cannot be used to enact a general federal criminal code.

Facts:

R.G. Harris and several other private individuals formed a conspiracy in Crockett County, Tennessee.
The purpose of the conspiracy was to deprive certain citizens of the equal protection of the laws of the State of Tennessee.
The acts of Harris and his co-conspirators were undertaken as private individuals, without any state authority or involvement.
The indictment against Harris contained no allegation that the State of Tennessee had passed any discriminatory laws or that its officials had taken any action to deny these citizens equal protection.

Procedural Posture:

The United States brought an indictment against R.G. Harris and others in the Circuit Court of the United States for the Western District of Tennessee.
The defendants were charged under Section 5519 of the Revised Statutes with conspiracy to deprive certain citizens of the equal protection of the laws.
The defendants filed a demurrer to the indictment, challenging the constitutionality of Section 5519.
The two judges of the Circuit Court were divided in their opinion on the constitutional question.
The Circuit Court certified the question of the law's constitutionality to the Supreme Court of the United States for a final decision.

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Issue:

Does Section 5519 of the Revised Statutes, which criminalizes conspiracies by private individuals to deprive any person of the equal protection of the laws of a State, exceed Congress's constitutional authority under the Thirteenth or Fourteenth Amendments?

Opinions:

Majority - Mr. Justice Woods

No. Section 5519 of the Revised Statutes is not a constitutional exercise of congressional power because Congress's authority under the Fourteenth Amendment is restricted to state action, and the Thirteenth Amendment does not grant Congress police power over the general criminal conduct of private citizens. The court reasoned that the government of the United States is one of enumerated powers and any act of Congress must find its warrant in the Constitution. The Fourteenth Amendment, by its explicit text ('No State shall...'), acts as a restraint on state governments, not on private individuals. Citing precedent like United States v. Cruikshank and Virginia v. Rives, the Court affirmed that the duty to protect citizens from the private criminal acts of other citizens remains with the states. As Section 5519 is directed exclusively against the actions of private persons, it cannot be sustained under the Fourteenth Amendment. The Court then found the statute was also too broad to be justified by the Thirteenth Amendment, which abolished slavery. The law was not limited to conspiracies based on race or prior servitude; it would punish a conspiracy of white citizens against another white citizen, which has no connection to slavery. Citing United States v. Reese, the Court held that a statute that is unconstitutionally overbroad cannot be narrowed by judicial interpretation and must be struck down in its entirety.

Dissenting - Mr. Justice Harlan

Justice Harlan dissented only on the procedural question of the Court's jurisdiction. He expressed no opinion on the merits of the case regarding the constitutionality of the statute.

Analysis:

This decision significantly narrowed the scope of federal power to protect civil rights in the post-Reconstruction era. By cementing the 'state action doctrine' for the Fourteenth Amendment, the Court effectively barred Congress from legislating against private racial violence and discrimination, such as the acts of the Ku Klux Klan. This ruling, along with United States v. Cruikshank and the Civil Rights Cases, relegated the protection of citizens from private infringement of their rights to the states, which were often unable or unwilling to provide it. The decision created a major obstacle to federal civil rights enforcement that persisted for nearly a century until it was later reinterpreted or circumvented through other constitutional powers, such as the Commerce Clause.

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