On June 30, 1952, during testimony in the case of United States v. Schneiderman, Oleta O'Connor Yates, an admitted leader of the Communist Party of California, refused to answer eleven questions regarding the identities of other members of the party. For her refusal Yates was found in criminal contempt and sentenced to eleven concurrent sentences of one year. The judge in the case stated that if Yates answered the questions within sixty days of conviction, he would accept her testimony. Yates continued to refuse.
Yates appealed the contempt convictions on the ground that the court's intention was to coerce her to testify, rather than punish her. This would make the contempt charges civil, rather than criminal, and Yates' convictions would be a violation of due process. Yates further claimed that eleven contempt sentences for a line of questioning also violated due process. The U.S. Ninth Circuit Court of Appeals rejected Yates' claims and upheld her convictions.
Did Yates' contempt convictions violate the Due Process Clause of the Fifth Amendment?
In a 6-3 decision authored by Justice Tom C. Clark, the Court found that Yates' contempt convictions were indeed criminal, but also found that eleven convictions for what amounted to a single instance of contempt violated due process. The judge in the case stated that, were Yates to concede to answer the questions, she would still be held for contempt, even though the court would accept her testimony. This, the Court reasoned, indicated that the convictions were intended to punish Yates and not to coerce her testimony.
However, the Court also found that every question for which Yates was found in contempt "fell within the same area of refusal." Noting that it would be improper for the prosecution to multiply contempts by repeated questioning on the same inquiry, the Court vacated all but the first conviction for contempt.
Decisions
Decision: 6 votes for Yates, 3 vote(s) against Legal provision:
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Full Opinion by Justice Tom C. Clark
