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Legal Principle at Issue

This case draws into question the constitutionality a section of the Subversive Activities Control Act of 1950,which provides that, when a Communist-action organization is under a final order to register, it shall be unlawful for any member of the organization "to engage in any employment in any defense facility."

Action

The Court ruled in favor of Robel, holding that the law was unconstitutional because it infringed on the First Amendment right of association. The statute's broad prohibition swept too far, criminalizing mere membership in an organization without requiring proof that the individual had engaged in or intended to engage in any illegal activity. The Court emphasized the importance of narrow tailoring: Even in matters of national security, constitutional protections do not disappear.

Facts/Syllabus

The case involved Eugene Frank Robel, an employee at a shipyard engaged in defense work. He was also a member of the Communist Party USA, which at the time was considered a subversive organization under the Subversive Activities Control Act of 1950 (specifically, the McCarran Act). The law made it illegal for members of such organizations to work in defense facilities once the group had been ordered to register with the Subversive Activities Control Board. Robel was indicted for violating this law because he continued working at the shipyard despite his Communist Party membership.

Importance of Case

United States v. Robel is a foundational case affirming that national security concerns do not override all constitutional protections, especially the First Amendment, and it illustrates the Supreme Court’s commitment to ensuring that laws targeting "subversive" threats do not criminalize lawful political beliefs or associations.