Law School Case Brief
NAACP v. Claiborne Hardware Co. - 458 U.S. 886, 102 S. Ct. 3409 (1982)
Civil liability may not be imposed merely because an individual belonged to a group, some members of which committed acts of violence. For liability to be imposed by reason of association alone, it is necessary to establish that the group itself possessed unlawful goals and that the individual held a specific intent to further those illegal aims. In this sensitive field, the state may not employ means that broadly stifle fundamental personal liberties when the end can be more narrowly achieved.
In 1966, a boycott of white merchants in Claiborne County, Mississippi, was launched at a meeting of a local branch of the National Association for the Advancement of Colored People (NAACP) attended by several hundred black persons. The purpose of the boycott was to secure compliance by both civic and business leaders with a lengthy list of demands for equality and racial justice. The boycott was largely supported by speeches encouraging nonparticipants to join the common cause and by nonviolent picketing, but some acts and threats of violence did occur. In 1969, respondent white merchants filed suit in Mississippi Chancery Court for injunctive relief and damages against petitioners (the NAACP, the Mississippi Action for Progress, and a number of individuals who had participated in the boycott, including Charles Evers, the field secretary of the NAACP in Mississippi and a principal organizer of the boycott). Holding petitioners jointly and severally liable for all of respondents' lost earnings during a 7-year period from 1966 to the end of 1972 on three separate conspiracy theories, including the tort of malicious interference with respondents' businesses, the Chancery Court imposed damages liability and issued a permanent injunction. The Mississippi Supreme Court rejected two theories of liability but upheld the imposition of liability on the basis of the common-law tort theory. Based on evidence that fear of reprisals caused some black citizens to withhold their patronage from respondents' businesses, the court held that the entire boycott was unlawful and affirmed petitioners' liability for all damages "resulting from the boycott" on the ground that petitioners had agreed to use force, violence, and "threats" to effectuate the boycott.
Did the lower courts err in holding that the entire boycott conducted by the petitioners was unlawful?
The United States Supreme Court reversed the judgment of the lower court contending that the majority of petitioners' activities were nonviolent and entitled to the protection of the First Amendment. Therefore, the Court held that only those who took part in the unlawful activity could be held liable and only those losses proximately caused by the unlawful conduct could be recovered. The Court noted that absent a specific intent to further such unlawful conduct, mere association by petitioners with the boycotting group was insufficient to predicate liability.
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