did not analyze any of the 31 questions put to Scull, did not explain to Scull what the subject of the committee's inquiry was, and did not explain how these questions related to that inquiry. It was clear, Black held, that the questions put to Scull clearly involved the First Amendment rights of freedom of speech, freedom of the press, and freedom of association. The Court's long-established test in such cases was to determine if there was a compelling governmental interest which could justify infringement on these fundamental rights. But the majority did not need to reach even this constitutional question, Black concluded, because Thomson's, the committee's, and the circuit court's statements about the subject of inquiry were so unclear that Scull was prevented from knowing what he was supposed to answer. "To sustain his conviction for contempt under these circumstances would be to send him to jail for a crime he could not with reasonable certainty know he was committing." The Supreme Court had repeatedly held (Lanzetta v. New Jersey, 306 U.S. 451 [1939], Jordan v. De George, 341 U.S. 223 [1951], Watkins v. United States, 354 U.S. 178 [1957], Flaxer v. United States, 358 U.S. 147 [1958]) that "fundamental fairness" required that a reasonable certainty exist as to what crime an individual might be committing. Relying on Winters v. New York, 333 U.S. 507 (1948), Black concluded that such certainty is "essential" when individuals are asked to give up their freedom of speech, freedom of the press, and freedom of association out of a fear of violating a vague law. But the "far too wavering, confused and cloudy" responses given to Scull did not meet these standards. The Court reversed and remanded the case to the Virginia Supreme Court of Appeals. References Bibliography Anzalone, Christopher A. Supreme Court Cases on Political Representation, 1787-2001. Armonk, N.Y.: M.E. Sharpe, 2002. Duke, Daniel Linden. Education Empire: The Evolution of an Excellent Suburban School System. Albany, N.Y.: State University of New York Press, 2005. Virginia Supreme Court of Appeals. Cases Decided in the Supreme Court of Appeals of Virginia. Richmond, Va.: Virginia Dept. of Purchase and Supply, 1959. External links United States Supreme Court cases United States Supreme Court cases of the Warren Court United States Free Speech Clause case law Void for vagueness case law Virginia law 1959 in United States case law 1959 in Virginia