National Association For the Advancement of Colored People v. Alabama Ex Rel. Patterson

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357 U.S. 449 (1958), argued 15–16 Jan. 1958, decided 30 June 1958 by vote of 9 to 0; Harlan for the Court. In this case, the Supreme Court upheld the right to freedom of association as an integral part of the First Amendment despite the absence of an explicit reference to association in the amendment's wording.

The case arose in the context of the NAACP's noncompliance with Alabama corporate filing laws and its efforts to operate in the face of state legal action to oust it for activities (such as organizing a bus boycott and aiding students seeking to desegregate the state university) that were allegedly causing irreparable injury to the state's citizenry. The Alabama trial court sought to obtain numerous NAACP records and, after some delay, the NAACP produced all the required documentation except its membership list, asserting that to supply such a list would threaten its organizational integrity. Publicizing the names of its members would lead to economic and employment reprisals, harassment, violence, and similar burdens on its members’ associational and expressive freedom. A trial judge held the NAACP in contempt and fined it $100,000.

The Supreme Court held that the NAACP could assert the constitutional right of its members as a defense against the contempt charge. To require individual members to come forward and assert their associational rights would, in this instance, effectively negate them. More broadly, the Court found that the membership list was so related to the members’ rights to pursue their lawful interests privately, and to associate freely, as to be constitutionally protected. Forced disclosure of the membership list would unduly burden the NAACP's First Amendment freedom of association. Nor had the state demonstrated an interest in the list sufficient to outweigh the NAACP's constitutional objection. The Alabama court's contempt judgment and fine were overturned.

Elliot E. Slotnick

Subjects: Law.

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