National Association for the Advancement of Colored People v. State of Alabama, ex rel. Patterson

Brief Fact Summary. The National Association for the Advancement of Colored People (NAACP/Petitioner) was ordered to produce a membership list by the state court.

Synopsis of Rule of Law. Freedom of association to promote beliefs is insured by the Fourteenth Amendment and is protected by adherence to strict scrutiny of any regulatory interference.

Facts. Petitioner was ordered by a court to provide a full membership list, including names and addresses. Although Petitioner agreed to provide a list of its officers and paid staff members, it asserts that this list is protected and that it may assert the personal privacy interests of each of its members. Additionally, Petitioner claims that disclosure will serve as a restriction on lawful association of members that can only be justified by a compelling state interest.

Issue. Can the state compel disclosure of the membership list of the NAACP?

Held. No. Disclosure of the list will subject members to adverse consequences including economic, physical and other forms of public hostility. In essence, this will limit Petitioner’s members’ ability to advocate their beliefs, and it will dissuade others from joining the organization for fear of retribution.

Discussion. An association may assert the rights of its membership when the rights of the individual members are tightly interrelated to the interest of the association.