United States v. Price, 383 U.S. 787 (1966)

Facts

  • In June 1964, three civil rights workers (Michael Schwerner, James Chaney, and Andrew Goodman) were killed near Philadelphia, Mississippi.

  • Federal prosecutors charged 18 defendants, including Mississippi law enforcement officials and private individuals, with conspiring to deprive the victims of constitutional rights.

  • The alleged plan involved using official authority to detain the victims, release them at night, intercept them, assault and kill them, and dispose of their bodies.

  • Two indictments were returned:

    • One alleged a conspiracy under 18 U.S.C. § 371 to violate 18 U.S.C. § 242 and also charged substantive § 242 violations.
    • The other charged a conspiracy under 18 U.S.C. § 241 to interfere with rights secured by the Constitution.
  • The district court dismissed the substantive § 242 counts as to the private defendants on the ground they were not state officers, and dismissed the entire § 241 indictment as not reaching Fourteenth Amendment rights.

  • The United States took direct appeals from the dismissals.

Issues

  1. Whether private individuals who jointly participate with state officials may be prosecuted under 18 U.S.C. § 242 as acting “under color of” law.
  2. Whether 18 U.S.C. § 241 covers conspiracies to interfere with rights secured by the Fourteenth Amendment, including due process rights that presuppose state action.
  3. Whether the district court’s dismissal of the § 242 counts against private defendants was reviewable on direct appeal as a statutory-construction ruling.

Decision

  • The Supreme Court reversed the dismissal of the substantive § 242 counts against the private defendants and remanded.
  • The Court held that acting “under color of” law does not require official status; it is enough that a defendant is a willful participant in joint activity with the State or its agents.
  • The Court reversed the dismissal of the § 241 indictment and remanded, holding that § 241 extends to conspiracies to violate rights secured by the Fourteenth Amendment.
  • The Court held the § 242 dismissal was reviewable because it turned on an erroneous construction of § 242’s “under color of law” requirement rather than on pleading insufficiency.
  • Under 18 U.S.C. § 242, a private person may act “under color of” law when willfully participating in joint activity with state officials or agents.
  • The state-action component is satisfied when private defendants and officials act together so that the challenged conduct is fairly attributable to the State.
  • 18 U.S.C. § 241 reaches conspiracies to interfere with “any right or privilege secured or protected by the Constitution or laws of the United States,” including Fourteenth Amendment rights requiring state action.
  • A dismissal based on statutory interpretation of a criminal civil-rights statute may be subject to direct appellate review when it rests on the court’s construction of the statute’s scope.

Conclusion

The Court restored federal civil-rights charges by holding that private individuals who cooperate with officials can be prosecuted under § 242 as acting under color of law and that § 241 criminalizes conspiracies to violate Fourteenth Amendment rights, requiring further proceedings on remand.