Scull v. Virginia ex rel. Committee on Law Reform and Racial Activities, 359 U.S. 344 (1959), is a 9–0 ruling by the Supreme Court of the United States which held that a conviction violates the Due Process Clause of the Fourteenth Amendment to the United States Constitution if the defendant is not given an opportunity "to determine whether he was within his rights in refusing to answer" an inquiry put to him by the legislature of a U.S. state. Background The state of Virginia enacted a package of statutes in September 1956 designed to ensure racial segregation in that state's public schools despite the ruling of the Supreme Court of the United States in Brown v. Board of Education of Topeka, Kansas, 347 U.S. 483 (1954). The legislative program ("the Stanley Plan") was named for Governor Thomas B. Stanley, who proposed the program and successfully pushed for its enactment. The Stanley Plan was a critical element in the policy of "massive resistance" to the Brown ruling advocated by U.S. Senator Harry F. Byrd, Sr. The Stanley Plan was introduced and passed during a special session of the Virginia General Assembly. During the special session, Delegate James McIlhany Thomson, an ardent segregationist, introduced a bill (unrelated to the Stanley Plan) to establish a seven-member Assembly committee to investigate any group seeking to influence public opinion in the state, teacher quality, uniformity of courses and curriculum in the public schools, and the effects of integration on public education. The bill passed on the last day of the special session. The legislation established a 10-member Assembly committee composed of six delegates and four senators. The committee was charged with investigating the effect of integration on public schools, racial matters in the state in general, and the effectiveness of racial legislation. The committee was to issue a report and make recommendations (if any) to the Assembly by November 1, 1957. The legislative investigating committee was officially titled the Virginia Committee on Law Reform and Racial Activities, but was publicly known as the "Thomson Committee" after its chair, Delegate Thomson. In 1954, David Scull (a printer in Annandale, Virginia) began publishing literature in favor of racial integration on behalf of a number of organizations in Virginia. The Fairfax Citizens' Council, a group opposed to racial integration, publicized Scull's role in the printing of the literature in 1957. Scull was subpoenaed to appear before the Thomson