United States v. Brown 381 U.S. 437 (1965) was a decision of the US Supreme Court that upheld the rights of communists to hold leadership positions in labor unions.

The Landrum-Griffin Act (LMRDA) was a piece of McCarthy-era legislation meant to regulate the internal affairs of labor unions, passed in 1959.

Under section 504, members of the Communist Party and convicted felons were barred from holding union office.

[1][2] Archie Brown was elected to the executive board of the International Longshore and Warehouse Union, Local 10 (San Francisco) in the late 1950s.

In a decision authored by Chief Justice Earl Warren, section 504 of the LMRDA was found to constitute a bill of attainder that was unconstitutional under Article I, Section 9, Clause 3 of the Constitution.