United States v. Price

Cecil Ray Price (defendant), a Mississippi deputy sheriff, along with two other law-enforcement officers (officers) (defendants) and 15 civilians (defendants) carried out a conspiracy to assault and murder three civil rights workers. A federal grand jury returned two indictments against the group. Indictment No. 59 charged the 18 men with a felony violation of 18 U.S.C. § 241, a federal statute prohibiting two or more persons from conspiring to deprive a person of his rights under the Constitution of the United States or under federal law. Indictment No. 60 included several counts charging the 18 men with acting under color of state law to deprive the civil-rights workers of their Fourteenth Amendment due process rights in violation of 18 U.S.C. § 242. The district court sustained the relevant counts in Indictment No. 60 as to the law-enforcement officers but dismissed the counts as to the civilians, reasoning that the civilians had not acted under color of law. The district court also dismissed Indictment No. 59 in its entirety, holding that, pursuant to United States v. Williams, 341 U.S. 70 (1951) (Williams I), § 241 does not apply to Fourteenth Amendment violations. The United States (plaintiff) appealed the dismissals. The United States Supreme Court determined that the district court had erred in dismissing Indictment No. 60 as to the civilians. The Court held that private persons jointly engaged with state officials in a prohibited activity are acting under color of law for the purposes of § 242. The Court then turned its attention to Indictment No. 59.