United States v. Price et al.
383 U.S. 787 (1966)
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Rule of Law:
Private individuals who are willful participants in joint activity with state officials are acting "under color of law" for purposes of 18 U.S.C. § 242. Furthermore, 18 U.S.C. § 241, which criminalizes conspiracies to interfere with the free exercise of constitutional rights, applies to all rights secured by the Constitution, including Fourteenth Amendment due process rights.
Facts:
- On June 21, 1964, Cecil Ray Price, the Deputy Sheriff of Neshoba County, Mississippi, detained Michael Schwerner, James Chaney, and Andrew Goodman in the county jail.
- Price later released the three men from jail during the night.
- After their release, Price, along with Sheriff Rainey, Patrolman Willis, and 15 private individuals, intercepted the three men.
- The group removed Schwerner, Chaney, and Goodman from their vehicle and transported them to an unpaved road.
- The defendants then wilfully assaulted, shot, and killed all three men as a form of "punishment."
- One of the defendants subsequently transported and buried the victims' bodies near an earthen dam construction site.
Procedural Posture:
- The United States government secured two indictments against 18 defendants from a federal grand jury in the Southern District of Mississippi.
- Indictment No. 60 charged violations of 18 U.S.C. § 242 for depriving individuals of constitutional rights under color of law.
- Indictment No. 59 charged a conspiracy to violate civil rights under 18 U.S.C. § 241.
- In the U.S. District Court for the Southern District of Mississippi, the defendants moved to dismiss the indictments.
- The District Court dismissed the § 241 indictment (No. 59) entirely.
- For the § 242 indictment (No. 60), the court upheld the conspiracy count but dismissed the substantive counts against the 15 private (non-official) defendants.
- The United States government made a direct appeal to the Supreme Court of the United States challenging the dismissal of these charges.
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Issue:
Do federal civil rights statutes, 18 U.S.C. §§ 241 and 242, apply to a conspiracy of private individuals and state officials who murder individuals, thereby depriving them of their Fourteenth Amendment right to life and liberty without due process of law?
Opinions:
Majority - Justice Fortas
Yes. The federal civil rights statutes, 18 U.S.C. §§ 241 and 242, apply to conspiracies between state officials and private individuals to deprive persons of their Fourteenth Amendment rights. For § 242, private persons acting jointly with state officials are considered to be acting 'under color of law.' To act 'under color of law' does not require the accused to be an officer of the State; it is enough that they are a willful participant in joint activity with the State or its agents. In this case, the state officers' involvement in the detention, release, and murder of the victims made the entire venture an act of 'official lawlessness,' bringing the private co-conspirators under the statute. For § 241, the Court held that its plain language, which protects 'any right or privilege secured to him by the Constitution,' is not limited to rights flowing from the federal government but extends to all constitutional rights, including those guaranteed by the Fourteenth Amendment. The legislative history of the Enforcement Act of 1870 confirms Congress's intent to provide broad protection against conspiracies aimed at denying newly established Fourteenth Amendment rights, particularly the right to due process.
Concurring - Justice Black
Justice Black concurred in the judgment and the Court's opinion but disagreed with its reliance on the precedents set in the Williams cases.
Analysis:
This decision significantly expanded the federal government's power to prosecute civil rights violations, especially those involving collusion between private citizens and local law enforcement. By interpreting 'under color of law' in § 242 to include private actors in a joint venture with the state, the Court closed a major loophole that had protected vigilantes. Moreover, by definitively holding that § 241 applies to Fourteenth Amendment rights, the Court provided the Department of Justice with a powerful tool to prosecute conspiracies aimed at denying due process, which was critical for combating violence against civil rights workers when state authorities were either complicit or unwilling to prosecute.
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