United States v. Guest
United States Supreme Court
383 U.S. 745 (1966)
Guest and five other defendants were indicted under 18 U.S.C. § 241 for conspiring to injure, threaten, and intimidate African American citizens to prevent them from exercising Fourteenth Amendment rights to use public facilities, arising from the shooting of Lemuel Penn, an African American reserve officer. The defendants, previously acquitted of murder in Georgia state court, were then federally indicted; they successfully moved to dismiss the indictment in district court, arguing it alleged no violation of federal law because no state actors were involved in the private conspiracy. The Supreme Court granted certiorari.
Whether Congress may extend § 5 of the Fourteenth Amendment to regulate private defendants who are sufficiently involved with state officials.