354 U.S. 178 (1957), argued 7 Mar. 1957, decided 17 June 1957 by vote of 6 to 1; Warren for the Court, Clark in dissent, Burton and Whittaker not participating. Watkins, a labor union officer, appeared as a witness before a subcommittee of the Un-American Activities Committee of the House of Representatives. He was willing to answer any questions about himself and also about others whom he knew to be members of the Communist party, but he refused to answer questions about persons who may in the past have been, but were no longer, members of the party.
Watkins's conviction for contempt of Congress was set aside. Though the rationale for the decision may have been limited to the sub-committee as failure to state the subject under inquiry or to show the pertinence of the questions to the investigation, Watkins is especially important for its articulation of broad constitutional principles that place limits on the congressional power of investigation. The power of inquiry is not unlimited; there is no authority to expose the private affairs of individuals unless justified by a function of Congress; and it is not a function of Congress to engage in law enforcement (an executive function) nor to act as a trial agency (a judicial function). An inquiry may not be an end in itself but it must be in furtherance of a legitimate task of Congress. The Bill of Rights, said the Court, is applicable to congressional investigations. The public is entitled to be informed as to the workings of government, but this does not mean that Congress has the power to invade the private lives of individuals.
Milton R. Konvitz