United States v. Price (1965)
- Docket
- 59
- Decided
- 1965-01-01
- Category
- General
Summary
Question: Did Price and the other defendants violate federal law when they murdered three men on June 21, 1964? Conclusion: Yes. In a unanimous decision, Justice Abe Fortas reinstated the indictment against all defendants. First, Justice Fortas addressed 18 U.S. C.S. 242 as applied to the non-police officers. Here, he noted that private citizens can act under the color of law where they are joining state officials in engaging in prohibited actions, as they did in this case. Therefore, the “color of law” indictments should be reinstated against all of the defendants, not merely the police officers. Next, Justice Fortas addressed the alleged violation of 18 U.S.C.S. 241, the criminal conspiracy statute. Here, Justice Fortas stated that a criminal conspiracy, perpetrated in part by state officials, constitutes a state action and therefore falls under the United States’ authority granted by the Fourteenth Amendment. Justice Fortas then addressed the history of this statute, and the Fourteenth Amendment. To him, this history, including the civil war, racial violence, Klu Klux Klan, and voter intimidation, solidified his conclusion that the conspiracy statute was designed to be read against the backdrop of the Fourteenth Amendment. Justice Hugo L. Black concurred in this decision, noting some disagreement with the majority’s use of the case of United States v. Williams, 341 U.S. 58; United States v. Williams, 341 U.S. 70; and Williams v. United States, 341 U.S. 70. This case also inspired the 1988 film, Mississippi Burning .