NAACP v. State of Alabama ex rel. Patterson

Brief Fact Summary.

Alabama brought suit against the NAACP to reveal its Alabama members. The NAACP refused and was held in contempt. The NAACP appealed, arguing that the order violated the group’s and the members’ constitutional rights.

Synopsis of Rule of Law.

The First Amendment as incorporated by the Due Process Clause in the Fourteenth Amendment protects an association from being forced to reveal its members.

Facts.

Attorney General of Alabama (John Patterson) brought suit against the NAACP to reveal the list of its Alabama members and received a court order commanding the NAACP to comply. The NAACP refused and was held in contempt. The NAACP appealed, arguing that the order violated the group’s and the members’ constitutional rights.

The NAACP argued that having to reveal its membership rolls would infringe upon its members right to associate with one another.

Issue.

Can Alabama compel the NAACP to reveal to the state the names and addresses of all its Alabama members and agents, without regards to their positions and functions?

Held.

No. Compelling an association to reveal its membership lists is a violation of the Due Process Clause of the Fourteenth Amendment.

Discussion.

It is “beyond debate” that freedom to engage in association is inseparable from liberty assured by the Due Process Clause of the Fourteenth Amendment, which incorporates the First Amendment.

NAACP successfully showed that past revelations of its members exposed them to public hostility, and they did not argue that they were exempt from investigation or other laws. But Alabama did not show that its interest in learning the identities of the NAACP’s members outweighed the damage it would do to the members’ First Amendment rights.

In Shelton v. Tucker (1960), the Court held that a state law requiring that all teachers disclose their group memberships annually was unconstitutional.