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Tenney v. Brandhove, 341 U.S. 367, 71 S.Ct. 783, 95 L.Ed. 1019

Facts

William Brandhove brought this action in the United States District Court for the Northern District of California, alleging that he had been deprived of rights guaranteed by the Federal Constitution. The defendants are Jack B. Tenney and other members of a committee of the California Legislature, the Senate Fact-Finding Committee on Un-American Activities, colloquially known as the Tenney Committee. The action is based on sections 43 and 47(3) of Title 8 of the United States Code, which derive from statutes aimed at enforcing the Fourteenth Amendment. The Tenney Committee was constituted by a resolution of the California Senate on June 20, 1947, and Brandhove circulated a petition among members of the State Legislature in 1949, alleging that the Committee had used him to smear a political opponent. After he refused to testify at a hearing, he was prosecuted for contempt, which was later dropped when the jury failed to reach a verdict.

The defendants are Jack B. Tenney and other members of a committee of the California Legislature, the Senate Fact-Finding Committee on Un-American Activities, colloquially known as the Tenney Committee.

Issue

Did the actions of the Tenney Committee and its members constitute a violation of Brandhove's civil rights under the applicable statutes?

Did the actions of the Tenney Committee and its members constitute a violation of Brandhove's civil rights under the applicable statutes?

Rule

The privilege of legislators to be free from arrest or civil process for what they do or say in legislative proceedings is well established, and the Civil Rights statutes were not intended to impose liability on legislators for actions taken within the scope of their legislative duties.

The privilege of legislators to be free from arrest or civil process for what they do or say in legislative proceedings has taproots in the Parliamentary struggles of the Sixteenth and Seventeenth Centuries.

Analysis

The court determined that the Tenney Committee was acting within its legitimate legislative authority when it summoned Brandhove to testify. The court emphasized that legislative committees have the right to conduct inquiries and that the privilege of legislators is designed to protect the public good by allowing them to perform their duties without fear of legal repercussions. The court found that the actions taken by the committee did not exceed the bounds of legislative power, and thus, the civil rights statutes did not create liability for the defendants.

The court determined that the Tenney Committee was acting within its legitimate legislative authority when it summoned Brandhove to testify.

Conclusion

The Supreme Court reversed the judgment of the Court of Appeals and affirmed the dismissal by the District Court, concluding that the civil rights statutes did not impose liability on the committee or its members for their legislative actions.

The judgment of the Court of Appeals is reversed and that of the District Court affirmed.

Who won?

Jack B. Tenney and the Senate Fact-Finding Committee on Un-American Activities prevailed because the Supreme Court found that their actions were protected under legislative privilege and did not constitute a violation of civil rights.

The Court holds that the Civil Rights statutes were not intended to make legislators personally liable for damages to a witness injured by a committee exercising legislative power.

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