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Law School Case Brief

NAACP v. Ala. ex rel. Patterson - 357 U.S. 449, 78 S. Ct. 1163 (1958)

Rule:

Compelled disclosure of affiliation with groups engaged in advocacy may constitute as effective a restraint on freedom of association as the forms of governmental action in the cases above were thought likely to produce upon the particular constitutional rights there involved. The Supreme Court has recognized the vital relationship between freedom to associate and privacy in one's associations.

Facts:

In proceedings instituted by the Attorney General of Alabama in the State Circuit Court, Montgomery County, Alabama, the state attorney general sought to enjoin the National Association for the Advancement of Colored People (NAACP), an out of state, nonprofit, membership corporation, from conducting further activities within the state, and to oust the NAACP from the state. The state's claim was that the NAACP had failed to qualify to do business within the state by complying with the statute requiring foreign corporations to file their corporate charters with the Secretary of State and designate a place of business and an agent to receive service of process. The State Circuit Court, in separate orders, restrained the NAACP, pendente lite, from engaging in further activities within the state or taking any steps to qualify itself to do business therein, and required the NAACP to produce records and papers, including the names and addresses of all of the NAACP's Alabama members and agents. The NAACP ultimately produced all the data called for by the production order, except its membership lists, as to which it contended that the state could not constitutionally compel disclosure. The State Circuit Court adjudged the NAACP in contempt of the production order and imposed a fine therefor. The NAACP's petitions for certiorari to review the contempt judgment were dismissed, on successive occasions, by the Supreme Court of Alabama, first, for insufficiency of the NAACP's allegations, and second, on procedural grounds.

Issue:

Could the State compel the NAACP to disclose its membership lists without violating the association’s constitutional rights?

Answer:

No.

Conclusion:

The Court held that the immunity from state scrutiny of membership lists, which the NAACP claimed on behalf of its Alabama members, was so related to the right of the members to pursue their lawful private interests privately, and to associate freely with others in so doing, as to come within the protection of the Fourteenth Amendment. According to the Court, the state had fallen short of showing a controlling justification for the deterrent effect on the free enjoyment of the right to associate which disclosure of the membership lists was likely to have. As such, the Court reversed and remanded the lower court's decision.

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