When a congressional committee conducts an investigation, the due process clause requires that it must clearly articulate the subject matter of the investigation and that all questions must be pertinent to the investigation.

During the early years of the Cold War, the House Un-American Activities Committee asked broad-ranging questions of people suspected of having supported communist causes. John Watkins, a former labor leader, agreed to answer questions about his own relationship to the CommunistCommunism Party but refused to answer questions about whether his personal acquaintances had been affiliated with the party in the past. He angered the committee when he declared that the information was not relevant to the investigation. For his refusal to cooperate, he was convicted of contempt of Congress.Congressional power of investigation;Watkins v. United States[Watkins v. United States]

By a 6-1 vote, the Supreme Court reversed the conviction. Speaking for the Court, Chief Justice Earl WarrenWarren, Earl;Watkins v. United States[Watkins v. United States] emphasized that a congressional committee must clearly articulate the purposes of its investigation and that it cannot compel witnesses to answer questions without giving them a fair opportunity to learn whether an answer is required. A committee has no right to expose the private life of an individual unless justified by a legitimate function of Congress. Warren expressed concern, moreover, that the committee was threatening First Amendment values. Although recognizing that the power to conduct investigations was inherent in the legislative process, he insisted that Congress must respect the constitutional rights of witnesses when gathering information.

Barenblatt v. United States

Cold War

Congressional power of investigation

Contempt power of Congress

Due process, procedural