At the last term the United States Supreme Court in Ullmann v. United States upheld the constitutionality of paragraph (c) of a federal act of August 1954 which seeks to compel the testimony of communists and other political deviants. Paragraph (c) relates to witnesses before federal courts and grand juries. The Court specifically left open the question of the validity of paragraphs (a) and (b) relating to congressional witnesses. Justice Frankfurter delivered the Court's opinion. Justice Douglas, with the concurrence of Justice Black, wrote a dissent.
It is our purpose to consider the background, history and terms of this compulsory testimony act, the validity of the Court's decision, and the history, constitutionality and utility of such acts generally. We shall be particularly concerned with the testimony of political deviants.
O. J. Rogge,
Compelling the Testimony of Political Deviants,
Mich. L. Rev.
Available at: https://repository.law.umich.edu/mlr/vol55/iss2/2