Takeaway
In short, this case holds that a private conspiracy to drive people from a State, however grave the wrong, was not federally punishable absent a specific federal right or a direct interference with federal functions; the ordinary remedy lay with the States.
Twenty-five defendants were charged under § 19 of the Criminal Code with conspiring to injure, oppress, threaten, or intimidate persons in the exercise of rights secured by the Constitution or federal law. The indictment alleged that the defendants armed themselves, seized Arizona residents, held them, transported them by train into New Mexico, and released them there after threatening death or serious harm if they returned to Arizona.
The first and third counts described the victims as citizens of the United States and of Arizona; the second described them as United States citizens residing, but not citizens, of Arizona. Each count rested on the asserted federal right to reside peacefully in Arizona and to be free from unlawful deportation from Arizona to another State. The federal trial court quashed the indictment, holding that punishment of these wrongs belonged exclusively to the States. The Government directly appealed under the Criminal Appeals Act.
Issue #1
Whether Article IV's Privileges and Immunities Clause creates a federally protected right, enforceable against private persons, to reside peacefully in a State and to be free from forced expulsion from it.
Holding
No. Article IV protects against discriminatory state action; it does not make a private individual's interference with residence or movement a federal constitutional violation.
Reasoning
The Court began with the historical premise that peaceful residence, movement within a State, and ingress to and egress from a State were fundamental civil rights protected under state law. Before the Constitution, the States possessed both the authority and the duty to protect those rights against private wrongdoing.
The Articles of Confederation, and later Article IV, § 2 of the Constitution, addressed a narrower interstate problem: States could not treat citizens of other States as aliens or deny them the privileges their own citizens enjoyed. The constitutional provision preserved state authority over these civil rights while forbidding discriminatory state treatment of nonresidents.
Because Article IV is directed to state action, a private conspiracy to expel persons from Arizona did not itself violate a right secured by that provision. The Court relied on United States v. Harris and the Slaughter-House Cases for the principle that the Clause, like the Fourteenth Amendment, does not reach purely private conduct.
Issue #2
Whether the Constitution's structure, or a national right of interstate travel and residence, gave Congress power to criminalize this private forced transportation from Arizona to New Mexico.
Holding
No. The alleged conduct did not directly and necessarily interfere with a federal governmental function or with a right arising from such a function.
Reasoning
The Government argued that the Constitution as a whole, the creation of a national government, and the consequences of Union implied a federal power to punish forced removal across a state line. The Court rejected that implication because it would displace the States' traditional authority to protect their citizens' fundamental civil rights without identifying a constitutional grant of federal power.
Crandall v. Nevada did not compel a different result. That case involved a state tax that directly burdened citizens' ability to travel to the seat of the national government and thereby interfered with federal operations; it was therefore a case about impermissible state action affecting federal functions, not a general federal power to punish private interference with interstate movement.
The Court carefully reserved the possibility that Congress could restrain conduct involving interstate ingress or egress when that conduct directly and necessarily interferes with duties the United States must perform. But the indictment alleged a private wrong to persons' residence and movement, not interference with any identified federal duty, so § 19 could not sustain the prosecution.