HUTCHESON v. UNITED STATES

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Case Basics
Docket No. 
46
Petitioner 
Maurice A. Hutcheson
Respondent 
United States
Decided By 
Advocates
(for the petitioner)
(for the respondent)
Tags
Term:
Facts of the Case 

Maurice A. Hutcheson, a president of a labor union, refused to answer eighteen questions before the Senate Select Committee on Improper Activities in the Labor or Management Field. Although Hutcheson appeared to be concerned about the state using his words against him in a pending state criminal trial, he specifically waived his Fifth Amendment privilege against self-incrimination. Instead, he argued that the Committee only wanted to expose his wrongful acts, and that this exposure would violate his rights under the Due Process Clause of the Fifth Amendment because the Committee’s questions acted as a “pretrial” of the state charges.

The United States District Court for the District of Columbia found the union president guilty of contempt of Congress. On appeal, the United States Court of Appeals for the District of Columbia Circuit affirmed the judgment. Hutcheson appealed the appellate court’s decision.

Question 

Do questions at a Senate Committee Hearing that relate to the witnesses’ ongoing state criminal proceedings violate Due Process?

Conclusion 
Decision: 4 votes for United States, 2 vote(s) against
Legal provision: Due Process

No. In a 4-2 decision Justice John M. Harlan wrote for the majority and concluded that the Committee’s questions were not outside the scope of the Senate investigation, nor were the Committee’s questions asked simply to expose the union president’s criminal acts. The fact that state prosecutors could have used the answers to the questions in a pending state criminal trial did not violate Due Process. The Court did not allow the union president to attempt to invoke his Fifth Amendment privilege against self-incrimination because he had explicitly waived it in the Committee hearing.

Justice Earl Warren wrote a dissent stating that the opinion forced the union president to choose between invoking the privilege against self-incrimination, answering the questions truthfully and aiding state prosecutors, committing perjury, or refusing to answer and face contempt.

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HUTCHESON v. UNITED STATES. The Oyez Project at IIT Chicago-Kent College of Law. 13 December 2014. <http://www.oyez.org/cases/1960-1969/1961/1961_46>.
HUTCHESON v. UNITED STATES, The Oyez Project at IIT Chicago-Kent College of Law, http://www.oyez.org/cases/1960-1969/1961/1961_46 (last visited December 13, 2014).
"HUTCHESON v. UNITED STATES," The Oyez Project at IIT Chicago-Kent College of Law, accessed December 13, 2014, http://www.oyez.org/cases/1960-1969/1961/1961_46.