Barenblatt v. United States
Supreme Court of the United States
360 U.S. 109 (1959)
Lloyd Barenblatt (petitioner), a 31-year-old psychology instructor, was subpoenaed in 1954 to testify before a subcommittee of the House Un-American Activities Committee (HUAC), which was investigating alleged Communist infiltration into education. The subcommittee's interest arose from testimony by Francis Crowley, a former graduate-school roommate, who admitted belonging to a Communist-affiliated club at the University of Michigan and said Barenblatt had belonged too. By the time Barenblatt appeared, Vassar College had already declined to renew his teaching contract, so he testified as an unemployed private citizen. Barenblatt answered questions about his general background but refused to say whether he was or had ever been a member of the Communist Party, objecting that the inquiry into his political and religious beliefs and associational activities exceeded the committee's authority and violated the First, Fifth, Ninth, and Tenth Amendments and the separation of powers. The House cited him for contempt of Congress; he was convicted at a bench trial and sentenced to six months in prison and a $250 fine, and the D.C. Circuit affirmed over four judges' dissents.
Whether a congressional committee's authority to compel a witness to answer questions about his own Communist Party membership and associations, on pain of a contempt conviction, violates the witness's First Amendment rights to freedom of speech and association.