Law School Case Brief
Wooley v. Maynard - 430 U.S. 705, 97 S. Ct. 1428 (1977)
The right of freedom of thought protected by U.S. Const. amend. I against state action includes both the right to speak freely and the right to refrain from speaking at all. A system which secures the right to proselytize religious, political, and ideological causes must also guarantee the concomitant right to decline to foster such concepts. The right to speak and the right to refrain from speaking are complementary components of the broader concept of "individual freedom of mind."
Appellees George Maynard and his wife Maxine are followers of the Jehovah's Witnesses faith. The Maynards consider the New Hampshire State motto to be repugnant to their moral, religious, and political beliefs, and therefore assert it objectionable to disseminate this message by displaying it on their automobiles. Pursuant to these beliefs, the Maynards began early in 1974 to cover up the motto on their license plates. After Maynard was tried and convicted on three different occasions in the state district court, for violating a state law making it a misdemeanor knowingly to obscure the figures or letters on any number plate, the Maynards brought an action in the federal district court seeking injunctive and declaratory relief against enforcement of the New Hampshire laws that required display of the state motto on license plates and made it a crime to obscure such motto. The federal district court judge issued a temporary restraining order against arrests or prosecutions of the Maynards for obscuring the motto on license plates, and subsequently, a three-judge District Court, finding that the couple's First Amendment rights had been abridged, granted permanent injunctive relief. The State filed a direct appeal to the United States Supreme Court.
Could New Hampshire enforce criminal sanctions against individuals who obscure the state motto?
The Court affirmed the the judgment, holding that the state could not enforce criminal sanctions against the couple for obscuring the state motto, since the state's requirement that noncommercial vehicle license plates be embossed with the state motto invaded First Amendment rights and could not be justified as facilitating the identification of passenger vehicles or as promoting an appreciation of history, individualism, and state pride. According to the Court, U.S. Const. amend. I protected the right of individuals to hold a point of view different from the majority and to refuse to foster, in the way the state commanded, an idea they found morally objectionable.
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