Whitney v. California case brief

Whitney v. California case brief summary

274 U.S. 357 (1927)

CASE SYNOPSIS

Petitioner appealed a judgment of the District Court of Appeal of California that affirmed her conviction under the California Criminal Syndicalism Act based on her membership in and organization of the Communist Labor Party of California. Petitioner claimed that the Act and its application to her violated the Due Process and Equal Protection Clauses of U.S. Constitutional amendment XIV.

CASE FACTS
Petitioner sought review of a judgment affirming her conviction under the state Criminal Syndicalism Act. The conviction was based on her involvement with the Communist Labor Party of California, including membership in the party.

ARGUMENT
On appeal, petitioner claimed the Act and its application to her case violated the Due Process and Equal Protection Clauses of U.S. Constitutional amendment XIV.

DISCUSSION

• The Supreme Court affirmed the judgment upholding the conviction. 
• The court held that it had jurisdiction to review the state court's judgment where an order of the appeals court indicated that a federal question regarding the Act's constitutionality had been presented and decided. 
• The court held that the essence of the offense was the combining with others in an association for the accomplishment of desired ends through the advocacy and use of criminal and unlawful methods and that the Act was not an unreasonable or arbitrary exercise of the police power of the state that unwarrantably infringed any right of free speech, assembly, or association. 
• The Act, as applied, did not violate either the Due Process or Equal Protection Clauses of the Fourteenth Amendment.

CONCLUSION

The judgment upholding petitioner's conviction under the state Criminal Syndicalism Act based on her involvement with the Communist Labor Party was affirmed. The Act was not an unreasonable or arbitrary exercise of police power, unwarrantably infringing any right of free speech, assembly, or association.